EPA 260-R-09-006
October 2009
Toxic Chemical Release
Inventory Reporting Forms
and Instructions
Revised 2009 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
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Important Information for Reporting Year 2009
Table of Contents
New Information for Reporting Year 2009 v
Other Important Information for RY 2009 vi
TRI-ME2009 vii
Web Sites and Points of Contact for Assistance viii
A. General Information 1
A.I Who Must Report 1
A.2 How to Submit Forms 1
A.2.a. How to Submit Form R(s) and/or Form A(s) to EPA via the Internet (EPA's Central
Data Exchange (CDX)) 1
A.2.b How to Submit Paper Form R(s) and/or Form A(s) 2
A.3 Trade Secret Claims 3
A.4 Recordkeeping 3
A.5 How to Revise or Withdraw TRI Data 4
A.6 When the Report Must Be Submitted 6
A.7 How to Obtain the TRI Reporting Forms 6
B. How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A.... 7
B.I Full-Time Employee Determination 7
B.2 Primary NAICS Code Determination 7
B.2.a. Auxiliary Facilities 10
B.2.b. Multi-establishment Facilities 10
B.2.c. Property Owners 11
B.3 Activity Determination 11
B.3.a. Definitions of Manufacture, Process, and Otherwise Use 11
B.3.b. Persistent Bioaccumulative Toxic (PBT) 14
B.3.c. Activity Exemptions 15
B.4 Threshold Determinations 21
B.4.a. How to Determine if Your Facility Has Exceeded Thresholds 22
B.4.b. Threshold Determinations for On-Site Reuse Operations 23
B.4.c. Threshold Determinations for Ammonia 24
B.4.d. Threshold Determinations for Chemical Categories 24
B.4.e Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals 25
B.4.f Mixtures and Other Trade Name Products 25
B.5 Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
and Nitrate Compounds 26
C. Instructions for Completing TRI Form R 32
Parti. Facility Identification Information 32
Section 1. Reporting Year 32
Section 2. Trade Secret Information 32
Section 3. Certification 32
Section 4. Facility Identification 32
Section 5. Parent Company Information 34
Part II. Chemical Specific Information 35
Section 1. EPCRA Section 313 Chemical Identity 35
Section 2. Mixture Component Identity 36
Section 3. Activities and Uses of the EPCRA Section 313 Chemical at the Facility 36
Section 4. Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time
during the Calendar Year 38
Section 5. Quantity of the EPCRA Section 313 Chemical Entering Each Environmental
Medium On-site 39
Section 6. Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations.. 46
Toxics Release Inventory Reporting Forms and Instructions i
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Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods 55
Section 8. Source Reduction and Recycling Activities 62
D. Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds) 74
D.I What is the Form R Schedule 1? 74
D.2 Who is required to file a Form R Schedule 1? 74
D.3 What information is reported on the Form R Schedule 1? 74
E. Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form
A 77
E.I Alternate Threshold 77
E.2 What is the Form A Certification Statement? 77
E.3 What Is the Annual Reportable Amount? 77
E.4 Recordkeeping 78
E.5 Multi establishment Facilities 78
E.6 Trade Secrets 78
E.7 Metals and Metal Category Compounds 78
F. Instructions for Completing EPA Form A 80
Parti. Facility Identification Information 80
Section 1. Reporting Year 80
Section 2. Trade Secret Information 80
Section 3. Certification 80
Section 4. Facility Identification 80
Section 5. Parent Company Information 82
Part II. Chemical Identification 83
Section 1. Toxic Chemical Identity 83
Section 2. Mixture Component Identity 84
Index 85
Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2009
Figures
Figure 1. EPCRA Section 313 Reporting Decision Diagram 9
Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet 28
Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound
Thresholds 29
Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound
Thresholds 30
Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds
Chemical Category 31
Figure 3. Reporting EPCRA Section 313 Chemicals 38
Figure 4. Hypothetical Section6.2 Completed for Two Off-Site Locations 56
Figure 5. Hypothetical SectionTA 60
Tables
Table I NAICS Codes 1-1
Table II EPCRA Section 313 Chemical List (including chemical categories)
for Reporting Year 2009 II-l
Table III State Abbreviations III-l
Table IV Federal Information Processing Standards (FIPS) Codes IV-1
Appendices
Appendix A Federal Facility Reporting Information A-l
Appendix B Reporting Codes for EPA Form R and Instructions for Reporting Metals B-l
Appendix C Facility Data Profiles and Common Errors in Completing Form R Reports and Form A
Certification Statements C-l
Appendix D Supplier Notification Requirements D-l
Appendix E TRI State Contacts E-l
Appendix F TRI Regional Contacts F-l
Appendix G Other Relevant Section 313 Materials G-l
Appendix H Guidance Documents H-l
Appendix I Questions and Answers Regarding Facility Identification Information 1-1
Toxics Release Inventory Reporting Forms and Instructions iii
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iv Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2009
New Information for Reporting Year 2009
• Please note that this 2009 version of the Toxics Release Inventory (TRI) Reporting Forms and Instructions
document supersedes previous versions of the document.
• If you are submitting your Form R and/or Form A via TRI-MEweb, the facility's registered certifying
official must electronically sign the submission before it can be entered into the TRI database. Uncertified
electronic submissions will not be accepted, will prevent the submission from being processed, and will
result in a Notice of Significant Error (NOSE) if they remain uncertified after the July 1st reporting deadline.
A facility must respond to a Notice of Significant Error within 21 days of receipt. Failure to respond within
the initial 21 day requirement could result in the issuance of a Notice of Noncompliance (NON). A Notice
of Noncompliance is not included in a Facility Data Profile (FDP) and is mailed separately.
• This is a reminder that the TRI program is no longer supporting the desktop version of TRI-ME. EPA
will accept only TRI-MEweb or paper submissions for RY 2009. We encourage you to file reports
for RY 2009 using the TRI-MEweb application.
If you need to revise prior or current year data (RY2005-RY2009), we encourage you to
submit revisions using the TRI-MEweb application. This will give you quicker access to
your facility data profile.
• If you need to revise forms prior to RY2004, EPA will accept revisions on magnetic media
(e.g., CD, 3.5" disks) using the TRI-ME software or on paper forms.
For states not on the state data exchange, TRI-MEweb allows facilities to generate disk/CD
submissions for their state. However, please note, that submissions generated of such media
type using TRI-MEweb will not be accepted by EPA.
• TRI-MEweb will be available to all reporting facilities in RY 2009, including first-time filers. TRI-MEweb
is a web-based version of the popular TRI-Made Easy (TRI-ME) reporting software. Facility Technical
Contacts will be emailed an access key by February, 2010. The facility access key is used to load your
facility data if you have reported in prior years using TRI-ME software. Please note that, if you are using
TRI-MEweb for the first time, certifying officials must register for the application at https://cdx.epa.gov.
This registration requires the printing, completion, and mailing of an electronic signature agreement.
Please allow adequate time for the mailing and processing of this form, which is estimated to take a
minimum of five (5) business days.
TRI-MEweb can be accessed anywhere you have a connection to the Internet. Unlike the PC-based TRI-ME
software, TRI-MEweb requires no downloads or software installs. You no longer have to contact your
"system administrator" to get rights to install the software because it's on the Web!
TRI-MEweb is similar to its predecessor TRI-ME CD/desktop in that it assists you in preparing your forms,
but TRI-MEweb offers so much more. TRI-MEweb is not only an interactive, intelligent, user-friendly
reporting application; it also provides many new features:
• Enhanced Data Quality and Validation • Electronic withdrawals/revisions
assistance • Third Party Load
• Quick Lists • Multi-establishment reporting
• Enhanced Section 8 Calculator • First-time filer reporting
• Prior Year revision capability
• Trend Analysis Reports
To learn more about this new solution to TRI reporting, please visit http://www.epa.gov/tri.
Toxics Release Inventory Reporting Forms and Instructions
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• EPA is placing a renewed emphasis on data quality in TRI reports. Specifically, the Agency has found that
many facilities report inaccurate parent companies and/or DUNS numbers in Sections 4 and 5 of the TRI
reporting forms. EPA asks all facilities to verify the accuracy of facility and parent company information
(e.g., Dun and Bradstreet number, parent company name). Some tips for reporting accurate information
follow, and related questions and answers are provided in Appendix I.
A. To verify the accuracy of your facility and parent company Dun and Bradstreet number
and name, as required in Section 5 of both Form R and Form A, go to
https://www.dnb.com/product/dlw/form cc4.htm or call 1-888-814-1435 to verify your
information. Callers to the toll free phone number should understand that the Dun and
Bradstreet support representatives will need to verify that callers requesting the DUNS
number are an agent of the business. Dun and Bradstreet recommends knowing basic
information such as when the business originated, officer names, and the name, address, and
phone number for the facility.
B. Facilities reporting to TRI should also make sure they are providing the parent company
name and Dun and Bradstreet number of the parent company as of December 31st of the
reporting year.
• EPA is also looking at using quick lists to verify the names of publicly owned treatment works
(POTW) and off-site location RCRA ID's in Form R Part II Section 6.1. B and 6.2. These quick lists
will contain accurate facility location data that is registered and maintained by EPA's Federal
Registry System.
Other Important Information for RY 2009
• Early Data Release of 2009 TRI Reports. EPA has adopted a new strategy to provide the public
with quicker access to the Toxics Release Inventory (TRI) data. The facility locator tool
(http://www.epa.gov/tri-efdr/) provides early access to the individual forms submitted by
regulated facilities. The annual TRI National Analysis (Public Data Release) for RY 2008, which
includes summary data, analyses, and trends, will be released by the spring of 2010.
• EPA's Audit Policy. If you discover your facility is or may have been in violation of Section 313
of EPCRA (TRI Reporting), please refer to EPA's Policy entitled, "Incentives for Self-Policing:
Discovery, Disclosure, Correction, and Prevention of Violations" (Audit Policy), 65 FR 19618,
April 11, 2000. You may qualify for having all gravity based penalties waived if your facility
meets all nine (9) conditions of the Audit Policy. For more information on EPA's Audit Policy,
see the Agency's web site http://www.epa.gov/compliance/incentives/auditing/auditpolicy.html
• EPA's Small Business Compliance Policy. If you have 100 or fewer employees and discover
that your facility is or may have been in violation of Section 313 of EPCRA (TRI Reporting),
please refer to EPA's Small Business Compliance Policy. EPA will eliminate or significantly
reduce penalties for small businesses that meet the conditions of the Policy, including voluntarily
discovering violations and promptly disclosing and correcting them. This Policy implements
Section 223 of the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996. For
more information, see the Agency's web site
http://www.epa.gov/compliance/incentives/smallbusiness/index.html.
vi Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2009
TRI-MEweb 2009 Application
The TRI-MEweb 2009 application helps facilities in determining and completing their Emergency
Planning and Community Right-to-Know (EPCRA) Section 313 and Pollution Prevention Act (PPA)
Section 6607 obligations. TRI-MEweb is an interactive, intelligent, user-friendly web-based application
tool that guides facilities through the TRI reporting experience. By leading prospective reporters through
a series of logically ordered questions, TRI-MEweb streamlines the analysis needed to determine if a user
must complete a Form R Report or may complete Form A Certification Statement for a particular
chemical. For those facilities required to report, the software provides the user with guidance for each
data element on the reporting forms. Additionally, this web-based application has a one-stop guidance
feature, the TRI Assistance Library that allows users to search the statute, regulations, and many EPCRA
Section 313 guidance documents by key word. For the more experienced reporter, TRI-MEweb allows
direct data entry onto electronic versions of the Form R and Form A Certification Statement. TRI-MEweb
will check the data for common errors and then prepare the forms. All of the information contained in this
RY 2009 Reporting Forms and Instructions book is contained within TRI-MEweb application.
TRI-MEweb allows the user to submit the forms via the Internet through CDX. TRI-MEweb supports
submitting electronically over the Internet using EPA's CDX without mailing any paper to EPA.
Toxics Release Inventory Assistance Library (TRIAL)
TRIAL is a searchable, indexed file that contains the statutes, the regulations, and most of the key
guidance documents a facility is likely to need for TRI reporting. TRIAL is integrated into TRI-MEweb
help menu.
Can I Use TRI-MEweb if I Have My Own TRI Software?
Yes. Some facilities have their own software or use private commercially-available software to assist in
preparing their TRI reports. This "third party software" will need to be designed to produce XML data
files that match EPA's XML schema. These file formats can be found on the TRI home page at
http://www.epa.gov/tri. You may load these flat files directly into TRI-MEweb and then use TRI-MEweb
to check your forms for data quality errors. You can then also use TRI-MEweb to submit the forms to U.S.
EPA and your state.
Toxics Release Inventory Reporting Forms and Instructions vii
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Web Sites and Points of Contact for Assistance
Technical Support:
For TRI information and contacts for technical support refer to the "Contact Us" page at
http://www.epa.gov/tri/contacts/contacts.htm
Frequently Asked Questions (FAQ) Service:
TRI users can scan frequently asked questions or submit a new question through the TRI Programs' FAQ
service. Access to the service is available from the "Contact Us" page on the TRI web site:
http://www.epa.gov/tri/contacts/contacts.htm
TRI Reporting Materials:
You can use TRI-MEweb and the TRI Assistance Library to electronically search and read TRI guidance
documents, including this document. The TRI web site contains links and guidance on filling out and
submitting TRI reporting forms: http://www.epa.gov/tri/report/index.htm
TRI Regional Contacts:
EPA Regional Coordinators often work closely with reporting facilities in their area providing training,
outreach, and assistance in completing forms. For a list of TRI Regional Coordinators, see Appendix F.
TRI State Contacts:
EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a list of state-
designated Section 313 contacts, see Appendix E.
Mailing Addresses Associated with TRI Federal Reporting Requirements:
Please see Section A for specific information on what documents must be sent to the Federal government
when submitting Forms R and A, trade secret submissions, and data revision and withdrawal requests.
The addresses where documentation can be sent are provided below. Additional information is provided
in Section A and Appendix E with respect to separate state reporting requirements.
Forms R and A
When mailing by U.S. Postal Service, To send paper forms by certified mail or
send to: overnight mail (i.e. Fed Ex, UPS, etc.), send to:
TRI Reporting Center CGI Federal, Inc
P.O. Box 10163 c/o EPA Reporting Center
Fairfax, VA 22038 12601 Fair Lakes Circle
Fairfax, VA 22033
Also send a copy of the report to the state in which the facility is located. "State" also includes: the
District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, Marshall
Islands, the U.S. Virgin Islands, the Commonwealth of the Northern Mariana Islands, and any other
jurisdiction and Indian Country. Refer to Appendix E for the appropriate state submission
addresses.
Facilities located on Indian land should send a copy to the Chief Executive Officer of the applicable
Indian tribe. Some tribes have entered into a cooperative agreement with states; in this case, report
submissions should be sent to the entity designated in the cooperative agreement.
viii Toxics Release Inventory Reporting Forms and Instructions
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Important Information for Reporting Year 2009
Trade Secret Submissions
When mailing by U.S. Postal Service, send To send trade secret submissions by certified mail
to: or overnight mail (i.e. Fed Ex, UPS, etc.), send to:
EPCRA Substantiation Packages
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
Attention: EPCRA Substantiation Packages
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
703-227-7644
TRI Data Revision Requests
When mailing by U.S. Postal Service, send To send revision requests by certified mail or
to: overnight mail (i.e. Fed Ex, UPS, etc.), send to:
Attention: TRI Revision Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
Attention: TRI Revision Request
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
Withdrawal Requests
When mailing by U.S. Postal Service, send To send revision requests by certified mail or
to: overnight mail (i.e. Fed Ex, UPS, etc.), send to:
Attention: TRI Withdrawal Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
Attention: TRI Withdrawal Request
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
Toxics Release Inventory Reporting Forms and Instructions
IX
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^^ j^ X\r\. Section 313 of the Emergency Planning
Y\ /N, Ripht-to-KnowActof 1Q86 also Ktioi
1 IniTprl ^Tiii"ps
u micu tidies Superfund Amendments and Reauthor
Environmental Protection Agency
WHERE TO SEND COMPLETED FORMS: 1 . TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
This
revi
subi
TRI Facilit
I and Community
tm. as litle 111 of the TO xic Chei
izationAct
f ID Number
nical, Category or Generic Name
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix E)
, section only applies if you are Revision (enter up to two code(s)) Withdrawal (enter up to two code(s))
Trilled form otherwise leave blank
IMPORTANT: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1 . REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
DYes (Answer question 2.2; No (Do not answer 2.2
Attach substantiation forms') n^ ^ Co^;^n i)
T ,, . v^niti-yari Unsanitized
22 Is this copy sanitized | |
(Answer only if "YES" in 2. 1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and
complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:
SECTION 4. FACILITY IDENTIFICATION
4.1
Signature:
Date Signed:
TRI Facility ID Number
Facility or Establishment Name Facility or Establishment Name or Mailing Address (If different from street address) |
Street | Mailing Address 1
City/County/State/Zip Code Citv/State/Zic Code 1
4.2
4.3
4.4
4.5
4.6
This report contains information for: An entire 1 1 Part of a
(Important: Check a or b; check c or d if applicable) a- __ facility | | facility c' — —
Technical Contact Name
lelephon
Email Address
Public Contact Name
Telephon
Email Address
NAICS Code (s) Primary
tb« a. b.
d. e.
Dun & Bradstreet a.
Country (Non-US)|
A Federal 1 1 GOCQ
facility d. | |
e Number (include area code) |
e Number (include area code)|
f.
Number (s) (9 digits) b
SECTION 5. PARENT COMPANY INFORMATION
5.1
5.2
Name of Parent Company NA
Parent Company's Dun & Bradstreet Number NA
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
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FRI Facility ID Number
FORMR
PART II. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
Toxic Chemical, Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY (Important: DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY
(Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 | Process the toxic chemical: 3.3 | Otherwise use the toxic chemical:
a. Produce
mport
If produce or import
C. For on-site use/processing
d.LJ For sale/distribution
e I I As a byproduct
f | | As an impurity
a.L
b.[
c.[
d.[
e.F
As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
a. | | As a chemical processing aid
b. | | As a manufacturing aid
C. | | Ancillary or other use
SECTION 4.1
4.1
(Enter two digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
A. Total Release (pounds/year*)
(Enter a range code** or estimate)
B. Basis of Estimate
(enter code)
C. % From Stormwater
5.1
Fugitive or non-point
air emissions
NA
5.2
Stack or point
air emissions
NA
5.3
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 5.3 page number in this box. I I (example: 1,2,3, etc.)
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year.
** Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.
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PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE (continued)
NA
A. Total Release (pounds/year*) (enter range
code ** or estimate )
B. Basis of Estimate
(enter code)
5.4.1
Underground Injection onsite
to Class I Wells
5.4.2
Underground Injection onsite
to Class II-V Wells
5.5
Disposal to land onsite
5.5.1A
RCRA Subtitle C landfills
5.5.1B
Other landfills
5.5.2
Land treatment/application
farming
5.5.3A
RCRA Subtitle C
surface impoundments
5.5.3B
Other surface impoundments
5.5.4 Other disposal
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1. A Total Quantity Transferred to POTWs and Basis of Estimate
6 1 A 1 Total Transfers (pounds/year*)
(enter range code ** or estimate)
6.1. A.2 Basis of Estimate
(enter code)
6.1.B
POTW Name
POTW Address
City
State
County
Zip
6.I.B.
| POTW Name
POTW Address
City
State
County
Zip
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box I I and indicate the Part II, Section 6.1 page number in this box |
(example: 1,2,3, etc.)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
62. Off-Site EPA Identification Number (RCRA ID No.)
Off-Site Location Name
Off-Site Address
City
State
County
Zip
Country
(Non-US
Is location under control of reporting facility or parent company?
Yes
No
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
* For Dioxin or Dioxin-like compounds, report in grams/year
' Range Codes: A=l-10 pounds: B=l-499 pounds; C=500 - 999 pounds.
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PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)
A. Total Transfers (pounds/year*)
(enter range code**or estimate)
B. Basis of Estimate
(enter code)
c. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
6 2
Off-Site EPAIdentificationNumber(RCRAIDNo.)
Off-Site Location Name
Off-Site Address
City
State
County
Zip
Country
(Non-US)
Is location under control of reporting facility or parent company?
Yes
No
A. Total Transfers (pounds/year*)
(enter range code**or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Not Applicable (N A) -
Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
. General
Waste Stream
[enter code]
b. Waste Treatment Method(s) Sequence
[enter 3- or 4- character code(s)]
d. Waste Treatment Efficiency
[enter 2 character code]
7 A. la
7A.lb
7A.ld
7A2a
7A.2b
7A3a
7A.3b I
7A.2d
7A.3d
7A4a
7A.4b
7A.4d
7A5a
7A.5b
7A.5d
If additional pages of Part II, Section 6.2/7 A are attached, indicate the total number of pages in this box
and indicate the Part II, Section 6.2/7 page number in this box: | _ | (example: l,2,3,etc.)
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year
"Range Codes: A=l - 10 pounds; B=ll - 499 pounds C= 500-999 pounds.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0009
Approval Expires: 03/31/2011 Page 5 of 5
FORMR
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Not Applicable (NA) -
Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
1 I I
SECTION 1C. ON-SITE RECYCLING PROCESSES
Not Applicable (NA) -
Check here if no on-site recycling is applied to any waste
stream containing the toxic chemical or chemical category.
Recycling Methods [enter 3-character code(s)]
SECTION 8. SOURCE REDUCTION AND RECYLING ACTIVITIES
Column A
Prior Year
(pounds/year*)
Column B
Current Reporting Year
(pounds/year*)
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
8.1
8.1a
Total on-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
8.1b
Total other on-site disposal or other
releases
&lc
Total off-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
8.1d
Total other off-site disposal or other
releases
8.2
Quantity used for energy recovery
onsite
8.3
Quantity used for energy recovery
offsite
8.4
Quantity recycled
onsite
8.5
Quantity recycled offsite
8.6
Quantity treated onsite
8.7
Quantity treated offsite
8.8
Quantity released to the environment as a result of remedial actions, catastrophic events,
or one-time events not associated with production processes (pounds/year)*
8.9
Production ratio or activity index
8.10
Did your facility engage in any source reduction activities for this chemical during the reporting
year? If not, enter "NA" in Section 8.10.1 and answer Section 8.11.
Source Reduction Activities
[enter code(s)]
Methods to Identify Activity (enter codes)
8.10.1
8.10.2
b.
8.10.3
b.
8.10.4
b.
8.11
If you wish to submit additional optional information on source reduction, recycling, or pollution
control activities, check "Yes."
Yes
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
*For Dioxin or Dioxin-like compounds, report in grams/year.
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0010
Approval Expires: 03/31/2011 Page 1 o
United States
Environmental Protection Agency
TOXICS RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
P. O. Box 1513
Lanham, MD 20703-1513
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instruction in Appendix E)
TRI Facility ID Number
This section only applies if you are revising
or withdrawing a previously submitted form,
otherwise leave blank.
Revision (enter up to two code(s)
Withdrawal (enter up to two code(s)
IMPORTANT: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
I Yes (Answer question 2.2; I I No (Do not answer 2.2;
I Attach substantiation forms) | | Go to Section 3)
2.2
Is this copy | | Sanitized [
(Answer only if "YES" in 2.1)
Unsanitized
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable amount as defined in 40 CFR
372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was manufactured, processed, or otherwise used in an amount not exceeding 1
million pounds during this reporting year.
Name and offical title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name |
Facility or Establishment Name or Mailing Address (If different from street address) |
Street
Mailing Address |
City/County/State/Zip Code |
City/State/Zip Code |
Country (Non-US)
4.2 This report contains information for: (Important: Check cord if applicable)
DA Federal
facility d.
GOCO
4.3
Technical Contact Name
Telephone Number (include area code)
Email Address
4.4
Public Contact Name
Telephone Number (include area code)
Email Address
4.5
NAICS Code (s)
(6 digits)
Primary
a.
4.7
Dun & Bradstreet
Number (s) (9 digits)
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350 -2 (Rev. 10/2009) - Previous editions are obsolete.
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(IMPORTANT: Type or print; read instructions before completing form) Page of __
EPA FORM A
PART II. CHEMICAL IDENTIFICATION TRIFID
Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*
SECTION 1. TOXIC CHEMICAL IDENTITY Report _of _
i CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above)
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
i Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above)
. Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY Report of
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
, Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY Report of
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.1
, Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
. . Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
i^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~
*See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)
EPA Form 9350 -2 (Rev. 10/2009) - Previous editions are obsolete.
(Make additional copies of this page, if needed)
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires 04/30/2010
Page 1 of 4
FORM R Schedule 1
TRI Facility ID Number
United States
Environmental Protection RART II. CHEMICAL-SPECIFIC IN FORMATION (continued)
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
D. Mass (grams) of Each Compound in the category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions
5.2 NA
Stack or point
air emissions
5 , Discharges to receiving streams or water bodies
(enter data for one stream or water body per box)
5.3.1
If additional pages of Section 5.3 are attached, indicate the total number of pages in this bo;
and indicate the Section 5.3 page number in this box (example: 1,2,3, etc.)
5.3.2
<
5.3.3
EPA Form 9350-3
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Form Approved OMB Number: 2025-0007
Approval Expires 04/30/2010
Page 2 of 4
FORM R Schedule 1
TRI Facility ID Number
PART II. CHEMICAL-SPECIFIC IN FORMATION (continued)
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
C. Mass (grams) of Each Compound in the category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Underground Injection
5.4.1 NA
Underground
njection onsite
to Class I Wells
5.4.2 NA
Underground
Injection onsite
toClassll-V
Wells
5.5 Disposal to land onsite
5.5.1. A NA
RCRA Subtitle C
andfills
5.5.1. B NA
Other landfills
5.5.2 NA
Land treatment/
application farming
5.5.3A NA
RCRA Subtitle C
surface
impoundments
5.5.3B NA
Other surface
impoundments
5.5.4 NA
Other disposal
EPA Form 9350-3
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires:04/30/2010
Page 3 of 4
FORM R Schedule 1
TRI Facility ID Number
PART II. CHEMICAL-SPECIFIC INFORMATION (continued)
SECTION
6. TRANSFERS OF DIOXIN AND DIOXIN-LIKE COMPOUNDS IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A.3 Mass (grams) of Each Compound in the Category (1-17)
1
10
2
11
3
12
4
13
5
14
6
15
7
16
8
17
9
6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2.
1.
9
D. Mass (grams]
2.
9
3.
9
4.
9
6.2.
1.
9
9
9
9
1
10
1
10
1
10
1
10
2
11
2
11
2
11
2
11
3
12
3
12
3
12
3
12
of Each Compound in the Category (1-17)
D. Mass (grams)
2.
3.
4.
1
10
1
10
1
10
1
10
2
11
2
11
2
11
2
11
3
12
3
12
3
12
3
12
4
13
4
13
4
13
4
13
5
14
5
14
5
14
5
14
6
15
6
15
6
15
6
15
7
16
7
16
7
16
7
16
8
17
8
17
8
17
8
17
of Each Compound in the Category (1-17)
If additional pages of Section 5.3 are attached, indicate the tota
and indicate the Section 5.3 page number in this box
4
13
4
13
4
13
4
13
5
14
5
14
5
14
5
14
I number of pages in this box
(example: 1,2,3, etc.)
6
15
6
15
6
15
6
15
7
16
7
16
7
16
7
16
8
17
8
17
8
17
8
17
EPA Form 9350-3
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires:04/30/2010
Page 4 of 4
FORM R Schedule 1
PART II. CHEMICAL-SPECIFIC INFORMATION (continued)
TRI Facility ID Number
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES FOR DIOXIN AND DIOXIN-LIKE COMPOUNDS (current vear onlv)
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
8.1a
Total onsite
disposal to
Class 1
Underground
Injection
Wells,
RCRA Subtitle
C landfills, and
other landfills
8.1b
Total other
onsite disposal
or other
releases
8.1c
Total offsite
disposal to
Class 1
Underground
Injection
Wells,
RCRA Subtitle
C landfills, and
other landfills
8.1d
Total other
offsite disposal
or other
releases
8.2
Quantity used
for energy
recovery
onsite
8.3
Quantity used
For energy
recovery
offsite
8.4
Quantity
recycled
onsite
8.5
Quantity
recycled
offsite
8.6
Quantity
treated
onsite
8.7
Quantity
:reated
offsite
8.8
Quantity released
o the environment
as a result of
remedial actions,
catastrophic
events, or one-
ime events not
associated with
production
processes
EPA Form 9350-3
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General Information
A. General Information
Reporting to the Toxic Chemical Release
Inventory (i.e., Toxics Release Inventory (TRI)) is
required by Section 313 of the Emergency
Planning and Community Right to Know Act
(EPCRA, or Title III of the Superfund
Amendments and Reauthorization Act of 1986),
Public Law 99 499. The information contained in
the Form R constitutes a "report," and the
submission of a report to the appropriate
authorities constitutes "reporting."
The Pollution Prevention Act, passed into law in
October, 1990 (Pub. L. 101 508), added reporting
requirements to Form R. These requirements
affect all facilities required to submit Form R
under Section 313 of EPCRA. The data were
required beginning with reports for calendar year
1991.
Reporting is required to provide the public with
information on the releases and other waste
management of EPCRA Section 313 chemicals in
their communities and to provide EPA with
release and other waste management information
to assist the Agency in determining the need for
future regulations. Facilities must report the
quantities of routine and accidental releases, and
releases resulting from catastrophic or other one
time events of EPCRA Section 313 chemicals, as
well as the maximum amount of the EPCRA
Section 313 chemical on-site during the calendar
year and the amount contained in wastes managed
on-site or transferred off-site.
A completed Form R or Form A must be
submitted for each EPCRA Section 313 chemical
manufactured, processed, or otherwise used at
each covered facility as described in the reporting
rules in 40 CFR Part 372 (originally published
February 16, 1988, in the Federal Register and
November 30, 1994, in the Federal Register (for
Form A)).
A. 1 Who Must Report
• Section 313 of EPCRA requires that reports be
filed by owners and operators of facilities that
meet all of the following criteria.
• The facility has 10 or more full-time employee
equivalents (i.e., a total of 20,000 hours or
greater; see 40 CFR 372.3); and
• The facility is included in a North American
Industry Classification System (NAICS) code
listed in Table I. NAICS codes found in Table
I correspond to the following Standard
Industrial Classification (SIC) Codes: SIC 10
(except 1011, 1081, and 1094), 12 (except
1241), 20-39, 4911 (limited to facilities that
combust coal and/or oil for the purpose of
generating electricity for distribution in
commerce), 4931 (limited to facilities that
combust coal and/or oil for the purpose of
generating electricity for distribution in
commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of
generating electricity for distribution in
commerce), 4953 (limited to facilities
regulated under RCRA Subtitle C, 42 U.S.C.
Section6921 et seq.), 5169, 5171, and 7389
(limited to facilities primarily engaged in
solvents recovery services on a contract or fee
basis); and
• The facility manufactures (defined to include
importing), processes, or otherwise uses any
EPCRA Section 313 chemical in quantities
greater than the established threshold in the
course of a calendar year.
Executive Order 13423 extends these reporting
requirements to federal facilities, regardless of
their SIC or NAICS code.
A. 2 How to Submit Forms
Starting this reporting year, facilities can only use
TRI-MEweb or paper for submitting Form R(s)
and/or Form A(s).
A.2.a. How to Submit Form R(s)
and/or Form A(s) Electronically
to EPA via the Central Data
Exchange (Using the TRI-
MEweb Application)
The preferred method to report to TRI is by the
use of the TRI-Made Easy web (TRI-MEweb)
application via EPA's Central Data Exchange
(CDX). TRI-MEweb is an intelligent, web-based
version of the popular TRI-ME software. There are
several advantages to using TRI-MEweb. They are
Toxics Release Inventory Reporting Forms and Instructions
1
-------
as follows: your prior year data will be pre-
populated, electronic signature that allows for
paperless filing, higher data quality and instant
confirmation that EPA has received your
submission. Facilities will be able to submit
reports electronically via TRI-MEweb and submit
their forms through the Internet via CDX. CDX
allows facilities to file a paperless report,
significantly reducing data errors, and receive
instant receipt confirmation of their submission.
Facilities that use TRI-MEweb to submit through
the Internet via CDX, and reside in a state
participating in the TRI State Data Exchange, will
have their forms sent simultaneously to EPA and
their respective state officials via the
Environmental Information Exchange Network.
Once a TRI submission is certified, it will be
electronically forwarded to state officials and your
obligation to report to EPA and your state will be
satisfied.
EPA encourages you to use TRI-MEweb to submit
your TRI submission(s). TRI-MEweb allows you
to submit a completely paperless report to EPA
(Internet submissions are not available for trade
secret claims). If you choose to submit via the
Internet, do not send duplicate paper copies of the
reports to the data processing center. Please be
aware that if your facility does not reside in a state
participating in the TRI State Data Exchange,
submitting via the Internet does not satisfy your
state reporting requirements for your facility. You
must report to your state separately and in the
required format specified by your state.
Former TRI-ME desktop/CD filers that have
submitted their reports through CDX in prior
reporting years, will need to "edit your current
account profile" in their My CDX account to add
the new TRI-MEweb application into their CDX
account. In addition, any active registered
certifying official within TRI-ME desktop/CD will
also need to add TRI-MEweb into their CDX
account profile and list all TRIFIDs assigned to
the certifying official into their profile. All
assigned TRIFIDs will be listed in an electronic
signature agreement (ESA) document that will
need to be printed, signed and sent by mail to
EPA's Data Processing Center for approval.
ESA's typically require five (5) business days to
be processed and approved. ESA's for TRI-
MEweb are only required once for new certifiers
and for former TRI-ME desktop/CD active
certifying officials. ESA's needs to be approved
by EPA before a certifying official can proceed to
finalize the certification of a facility's Form R or
A submission and fulfill their EPCRA Section 313
reporting requirements.
For questions or additional information about
CDX, please see: http://www.epa.gov/cdx
A.2.b How to Submit Paper Form
R(s) and/or Form A(s)
It is EPA's ultimate goal to move away from
processing paper submissions and receive all TRI
submissions via CDX. Although EPA strongly
discourages paper submissions due to increased
possibility of errors, paper submissions are
currently still accepted. Paper submissions must be
sent to both EPA and the state (or the designated
official of an Indian tribe). If a report is not
received by both EPA and the state (or the
designated official of an Indian tribe), the
submitter is considered out of compliance and
subject to enforcement action. Facilities
submitting paper forms must use the current
reporting year forms; out-of-date forms will
considered out of compliance. Send paper forms
by regular mail to:
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
Send paper forms by certified mail or overnight
mail (i.e. Fed Ex, UPS, etc.) to:
CGI Federal, Inc
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
Also send a copy of the report to the state in which
the facility is located. "State" also includes: the
District of Columbia, the Commonwealth of
Puerto Rico, Guam, American Samoa, Marshall
Islands, the U.S. Virgin Islands, the
Commonwealth of the Northern Mariana Islands,
and any other jurisdiction and Indian Country.
Refer to Appendix E for the appropriate state
submission addresses.
Facilities located on Indian land should send a
copy to the Chief Executive Officer of the
applicable Indian tribe. Some tribes have entered
into a cooperative agreement with states; in this
case, report submissions should be sent to the
entity designated in the cooperative agreement.
Toxics Release Inventory Reporting Forms and Instructions
-------
General Information
A. 3 Trade Secret Claims
For any EPCRA Section 313 chemical whose
identity is claimed as trade secret, you must
submit to EPA two versions of the substantiation
form as prescribed in 40 CFR Part 350, published
July 29, 1988, in the Federal Register (53 FR
28772) as well as two versions of the EPCRA
Section 313 report. The current substantiation
form is available on the TRI website at
http://www.epa.gov/tri/report/index.htmtfforms.
One set of reports, the unsanitized version, must
provide the actual identity of the EPCRA Section
313 chemical. The other set of reports, i.e., the
"sanitized" version, must provide a generic class
or category for the chemical that is structurally
descriptive of the EPCRA Section 313 chemical. If
EPA deems the trade secret substantiation form
valid, only the sanitized set of forms will be made
available to the public.
Use the order form in this document to obtain
copies of the rule and substantiation form. Further
explanation of the trade secret provisions is
provided in Part I, Sections 2.1 and 2.2, and Part
II, Section 1.3, of the instructions.
In summary, a complete report to EPA for an
EPCRA Section 313 chemical claimed as a trade
secret must include all of the following:
• A completed unsanitized version of Form R or
Form A report including the EPCRA Section
313 chemical identity (staple the pages
together); and
• A sanitized version of a completed Form R or
Form A report in which the EPCRA Section
313 chemical identity items (Part II, Sections
1.1 and 1.2) have been left blank but in which
a generic chemical name that is structurally
descriptive has been supplied (Part II, Section
1.3) (staple the pages together); and
• A completed unsanitized version of a trade
secret substantiation form (staple the pages
together); and
• A sanitized version of a completed trade secret
substantiation form (staple the pages together).
Securely fasten all four reports together.
Some states also require submission of both
sanitized and unsanitized reports for EPCRA
Section 313 chemicals whose identity is claimed
as a trade secret. Others require only a sanitized
version. Facilities may jeopardize the trade secret
status of an EPCRA Section 313 chemical by
submitting an unsanitized version of the EPCRA
Section 313 report to a state agency or Indian tribe
that does not require unsanitized forms. You may
identify an individual state's submission
requirements by contacting the appropriate state
designated EPCRA Section 313 contact (see
Appendix E).
Where to send your trade secret submission
Please send only trade secret submissions to the
P.O. Box below. Send trade secret submissions by
regular mail to:
Attention: EPCRA Substantiation
Packages
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
Send trade secret submissions by certified mail or
overnight mail (i.e. Fed Ex, UPS, etc.) to:
Attention: EPCRA Substantiation
Packages
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
A.4 Recordkeeping
Sound recordkeeping practices are essential for
accurate and efficient TRI reporting. It is in the
facility's interest, as well as EPA's, to maintain
records properly.
Facilities must keep a copy of each report filed for
at least three years from the date of submission.
These reports will be of use when completing
future reports.
Facilities must also maintain those documents,
calculations, worksheets, and other forms upon
which they relied to gather information for prior
reports. In the event of a problem with data
elements on a facility's Form R or Form A report,
EPA may request documentation from the facility
that supports the information reported.
EPA may conduct data quality reviews of Form R
or Form A submissions. An essential component
of this process involves reviewing a facility's
Toxics Release Inventory Reporting Forms and Instructions
-------
records for accuracy and completeness. EPA
recommends that facilities keep a record for those
EPCRA Section 313 chemicals for which they did
not file EPCRA Section 313 reports.
A partial list of records, organized by year, that a
facility should maintain include:
• Previous years' EPCRA Section 313 reports;
• EPCRA Section 313 Reporting Threshold
Worksheets;
• Engineering calculations and other notes;
• Purchase records from suppliers;
• Inventory data;
• EPA (NPDES) permits and monitoring
reports;
• EPCRA Section312 Tier II Reports;
• Monitoring records;
• Flowmeter data;
• RCRA Hazardous Waste Generator's Report;
• Pretreatment reports filed by the facility with
the local government;
• Invoices from waste management companies;
• Manufacturer's estimates of treatment
efficiencies;
• RCRA manifests;
• Process diagrams that indicate emissions and
other releases; and
• Records for those EPCRA Section 313
chemicals for which they did not file EPCRA
Section 313 reports.
A. 5 How to Revise or Withdraw TRI
Data
EPA has received several questions relating to
withdrawing and revising TRI data submitted by
facilities, such as:
• What are the reasons for revising?
• How do I revise my submission?
• To whom should this request be sent?
Submitting a Request to Revise TRI Data
Facilities that filed a Form R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to revise a form that was
previously submitted, stored in the Toxics Release
Inventory Processing System (TRIPS), and made
available to the public through Envirofacts and
TRI Explorer. Facilities may request a revision for
one or more of the following reasons:
RR1 - New Monitoring Data
RR2 - New Emission Factor(s)
RR3 - New Chemical Concentration Data
RR4 - Recalculation(s)
RR5 - Other Reason(s)
The revision code(s) should be entered in the
"Revision" box on the first page of the reporting
form. You may enter up to two revision codes on
the form.
Please note that late submissions for chemicals not
reported in a previous reporting year are not
considered revisions for that year.
How do I revise my submission(s)?
If you have determined that your facility wishes to
revise a TRI submission, you must send your
revised report to EPA and the appropriate state
agency. For submitting a revision to EPA, please
use one of the following methods:
• EPA will accept revisions for Reporting
Year 2005 through current year via TRI-
MEweb and paper.
• EPA will accept all revisions prior to
Reporting Year 2004 and beyond on
magnetic media created using TRI-ME
software or paper.
1. TRI-MEweb. The preferred method for revising
TRI forms from Reporting Year 2005 through the
current year is to use TRI-MEweb. For more
information regarding access to TRI-MEweb,
please visit http://www.epa.gov/tri. TRI-MEweb
provides several advantages compared to hard-
copy reporting, such as pre-populating the form
with the previous year's data, allowing reporters to
electronically sign and submit the form over the
Internet, providing automated data quality checks,
and electronically confirming EPA's receipt of a
submitted form. If you have questions about
accessing TRI-MEweb, please refer to the TRI-ME
web page at
http://www.epa.gov/tri/report/software/index.htmtf
usetrime
2. Hard Copy Form. EPA strongly discourages
paper submissions due to the increased possibility
of data entry errors; however, if necessary, you
may revise a previously submitted hard-copy form
Toxics Release Inventory Reporting Forms and Instructions
-------
General Information
or revisions for Reporting Year 2004 and beyond
by using either 1) a photocopy of the original or 2)
a blank form.
• Photocopy of Original Submission. You may
submit a photocopy of your original
submission (from your file) with the
corrections made in blue ink. Please re-sign
and re-date the certification statement on Page
1. For RY 2007 revisions and beyond, please
enter the appropriate revision code(s). For RY
2006 and prior years, please enter an "X" in
the space marked "Enter 'X' here if this is a
revision," on Page 1 of the form.
• Blank Form. Hard copy submissions may be
submitted using the form applicable for that
particular reporting year or the most recent
form available. You can request prior year
reporting forms at tridocs@epa.gov. For RY
2007 revisions and beyond, please enter all
information including the appropriate revision
code(s). For RY 2006 and prior years, please
enter all information including an "X" in the
space marked "Enter 'X' here if this is a
revision," on Page 1 of the form. Please sign
and date the certification statement on Page 1.
Send revision requests by regular mail to the
following address:
Attention: TRI Revision Request
TRI Reporting Center
P.O. Box 10163
Farifax, VA 22038
Send revision requests by certified mail or
overnight mail to the following address:
Attention: TRI Revision Request
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
Submitting a Request to Withdraw TRI Data
Facilities that filed a Form R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to withdraw a form that was
previously submitted, stored in the Toxics Release
Inventory Processing System (TRIPS), and made
available to the public through Envirofacts and
TRI Explorer. EPA may periodically review
withdrawals. Facilities may request a withdrawal
for one or several reasons, such as:
• WT1 - Did not meet the reporting threshold
for manufacturing, processing, or otherwise
use
• WT2 - Did not meet the reporting threshold
for number of employees
• WT3 - Not in a covered NAICS Code
• WO1 - Other reason(s)
The withdrawal code(s) should be entered in the
"Withdrawal" box on the first page of the
reporting form. You may enter up to two
withdrawal codes on the form.
How do I withdraw my submission(s)?
If you have determined that your facility wishes to
withdraw a TRI submission, you must send your
request to EPA and the appropriate state agency.
For submitting a withdrawal to EPA, please use
one of the following methods:
1. TRI-MEweb. The preferred method for
requesting a withdrawal of a previously submitted
TRI form from Reporting Year 2005 through the
current year is TRI-MEweb. For more information
regarding access to TRI-MEweb, please visit
http://www.epa.gov/tri/report/software/index.htmtf
usetrime
2. TRI-ME via CDX. For the RY 2002 through
2004 versions of the software, withdrawals may be
submitted electronically using the TRI-ME
software and submitting the report via CDX and
the Internet. You can download the TRI-ME
software at http ://www.epa. gov/tri
3. Hard Copy Form. All other withdrawal
requests may be submitted by hard copy as
follows:
• Reporting Year 2007 Forward. You may
submit a photocopy of your original
submission (from your file). Using blue ink,
re-sign and re-date the certification statement
on Page 1 and enter the appropriate
withdrawal code(s) in the space provided on
Page 1 of the form.
• Reporting Year 2006 and Prior Years. Please
submit a photocopy of the form you wish to
Toxics Release Inventory Reporting Forms and Instructions
-------
withdraw (from your file), and attach - as a A. 7 HOW to Obtain the TRI
cover page - Page 1 of the current year's
reporting form, which includes a field for the
withdrawal codes. Using blue ink, please sign
and date the certification statement and enter
all information including the appropriate
withdrawal code(s) in the space provided on
Page 1 of the current year's form.
Send withdrawal requests by regular mail to the
following address:
Attention: TRI Withdrawal Request
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
Send withdrawal requests by certified mail or
overnight mail to the following address:
Attention: TRI Withdrawal Request
CGI Federal, Inc
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
A. 6 When the Report Must Be
Submitted
As specified in EPCRA Section 313, the report for
any calendar year must be submitted on or before
July 1 of the following year whether using Form R
or Form A. If the reporting deadline falls on a
Saturday or Sunday, EPA will accept the forms
which are postmarked on the following Monday
(i.e., the next business day). If you submit using
TRI-MEweb via the Central Data Exchange
(CDX), you will receive your Facility Data Profile
(FDP) in an expedited fashion. Any voluntary
revision to a report can be submitted anytime
during the calendar year for the current or any
previous reporting year. However, voluntary
revisions for the current reporting year should be
submitted by July 31 in order to be included in that
year's TRI National Analysis. Always remember
to review your FDP. The FDP presents the
information you have submitted to EPA. If the
Technical Contact provided an email address in
the Form R/Form A, they will receive an email
notifying them when their FDP has been updated
and posted to the FDP website. You can retrieve
your FDPs at http://www.triefdp.org. If you have
questions regarding your FDP, please send an e-
mail to tri.efdp@epacdx.net or call 703-227-7644.
Reporting Forms
Copies of both forms are included in the first part
of this document. The forms and related guidance
documents may also be obtained from EPA's TRI
web site: http://www.epa.gov/tri
Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B. How to Determine if Your
Facility Must Submit a
Form R or Is Eligible to
Use Form A
This section will help you determine whether you
must submit an EPCRA Section 313 report (EPA
Form R or Form A Certification Statement). This
section discusses EPCRA Section 313 reporting
requirements such as the number of full-time
employees, primary NAICS code, and chemical
activity threshold quantities. The EPCRA Section
313 chemicals and chemical categories subject to
reporting are listed in Table II (also see 40 CFR
372.65). (See Figure 1 for more information.)
B.I Full-Time Employee
Determination
The number of full-time employees is dependent
only upon the total number of hours worked by all
employees and other individuals (e.g., contractors)
for the facility during the calendar year and not the
number of persons working. Therefore, a full-time
employee, for purposes of EPCRA Section 313
reporting, is defined as 2,000 work hours per year.
When making the full-time employee
determination, the facility must consider all paid
vacation and sick leave used as hours worked by
each employee. In addition, EPA interprets the
hours worked by an employee to include paid
holidays. To determine the number of full-time
employees working for your facility, add up the
hours worked by all employees during the
calendar year, including contract employees and
sales and support staff working for the facility, and
divide the total by 2,000 hours. The result is the
number of full-time employees. In other words, if
the total number of hours worked by all employees
for your facility is 20,000 hours or more, your
facility meets the ten employee threshold.
Examples:
• A facility consists of 11 employees who each
worked 1,500 hours for the facility in a
calendar year. Consequently, the total number
of hours worked by all employees for the
facility during the calendar year is 16,500
hours. The number of full-time employees for
this facility is equal to 16,500 hours divided
by 2,000 hours per full-time employee, or 8.3
full-time employees. Therefore, even though
11 persons worked for this facility during the
calendar year, the number of hours worked is
equivalent to 8.3 full-time employees. This
facility does not meet the employee criteria
and is not subject to EPCRA Section 313
reporting.
• Another facility consists of six workers and
three sales staff. The six workers each worked
2,000 hours for the facility during the calendar
year. The sales staff also each worked 2,000
hours during the calendar year although they
may have been on the road half of the year. In
addition, five contract employees were hired
for a period during which each worked 400
hours for the facility. The total number of
hours is equal to the time worked by the
workers (12,000 hours), plus the time worked
by the sales staff for the facility (6,000 hours),
plus the time worked by the contract
employees (2,000 hours), or 20,000 hours.
Dividing the 20,000 hours by 2,000 yields 10
full-time employees. This facility has met the
full-time employee criteria and may be subject
to reporting if the other criteria are met.
B. 2 Primary NAICS Code
Determination
Beginning with 2006 EPCRA Section 313
reporting, the TRI Program requires North
American Industry Classification System (NAICS)
codes instead of Standard Industrial Classification
(SIC) codes. Please refer to the TRI Program's
final rule titled Community Right-to-Know; Toxic
Chemical Release Reporting Using North
American Industry Classification System (NAICS)
published in the Federal Register on June 6, 2006
(71FR32464).
Beginning with Reporting Year 2008, facilities
should use 2007 NAICS codes. EPA published a
final rule on June 9, 2008 to incorporate 2007
Office of Management and Budget (OMB)
revisions and other corrections to the NAICS
codes used for TRI Reporting. [Federal Register
(FR) notice 73 FR 32466.] With this rule, facilities
are required to use 2007 NAICS codes on TRI
reporting forms that are due on July 1, 2009,
covering releases and other waste management
quantities at the facility for 2008.
The full list of NAICS codes for facilities that
must report to TRI (including exceptions and/or
Toxics Release Inventory Reporting Forms and Instructions
-------
limitations) if all other threshold determinations
are met can be found in Table I and also at the TRI
web site at
http://www.epa.gov/tri/lawsandregs/naic/ncodes.ht
m.
http://www.epa.gov/tri/lawsandregs/naic/ncodes.ht
m The facility should determine its own NAICS
code (s), based on its activities on-site, using the
NAICS Manual and by referring to the extensive
OMB crosswalk tables found on the Census
Bureau website: http: //www. census. gov. State
agencies and other organizations may assign
NAICS codes on a different basis than the one
used by the SIC Manual. However, for purposes of
EPCRA Section 313 reporting, these state
assigned codes should not be used if they differ
from ones assigned using the NAICS Manual.
The TRI Information Center can assist facilities
with determining which NAICS codes are
assigned for specific business activities as
referenced in the NAICS Manual. Clothbound
editions of the NAICS Manual are available in
most major libraries or may be ordered through the
National Technical Information Service, 5285 Port
Royal Road, Springfield, VA 22161, 703-605
6000. The access number for the hardbound
manual is PB2002-101430, $49.00+ shipping and
handling. The access number for the CD-ROM
version with search and retrieval software is
PB2002-502024, $60 + shipping and handling.
Paperwork Reduction Act Notice: The annual public burden related to the Form R, which is
approved under OMB Control No. 2070-0093, is estimated to average 29.6 hours per response
for non-PBT chemicals and 51.3 hours per response for PBT chemicals. The annual public
burden related to the Form A, which is approved under OMB Control No. 2070-0143, is
estimated to average 20.5 hours per response for a facility filing on one non-PBT chemical, and
35.89 hours per response for a facility filing on one PBT chemical.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing ways to
comply with any previously applicable instructions and requirements; train personnel to be able
to respond to a collection of information; search data sources; complete and review the
collection of information; and transmit or otherwise disclose the information. An agency may
not conduct or sponsor, and a person is not required to respond to, a collection of information
unless it displays a currently valid OMB control number. The OMB control numbers for EPA's
regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.
Send comments on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including
through the use of automated collection techniques, to the Director, Collection Strategies
Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW,
Washington, D.C. 20460; and to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA. Include the EPA ICR number and OMB control number in any
correspondence.
The completed forms should be submitted in accordance with the instructions
accompanying the form, or as specified in the corresponding regulation.
Toxics Release Inventory Reporting Forms and Instructions
-------
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Does your facility have 10 or more full-
time employees or the equivalent?
(see definition under B.I)
YES
Is your facility's primary NAICS Code
included on the EPCRA Section 313
list? Or is your facility a Federal facility?
(see B.2 and Table 1)
YES
Does your facility manufacture, process, or
otherwise use EPCRA Section 313
chemicals and chemical categories?
(see Table II, B.3-B.5, and D.1-D.7)
YES
Does your facility exceed any of the
thresholds for a chemical or chemical
category (after excluding quantities that
are exempt from threshold calculations)
YES
AN EPCRA SECTION 313 REPORT
IS REQURED FOR THE CHEMICAL OR
CTTFMTC AT, C ATFYIORV
YES
Is this chemical or chemical category identified
as Persistent, Bioaccumulative, and Toxic
(PBT)?
YES
NO
NO
NO
NO
NO
STOP
NO EPCRA SECTION
313 REPORTS
REQUIRED FOR ANY
CHEMICALS
Is the amount manufactured, OR processed, OR otherwise used less than
or equal to 1,000,000 pounds and is the reportable amount less than or
equal to 500 Ibs/year?
NO
YES
FORM R IS REQUIRED FOR THIS
CHEMICAL OR CHEMICAL
CATEGORY (FORM A CANNOT BE
SUBMITTED)
FORM A OR FORM R IS REQUIRED
FOR THIS CHEMICAL CATEGORY
Figure 1. EPCRA Section 313 Reporting Decision Diagram
Toxics Release Inventory Reporting Forms and Instructions
-------
B.2.a. Auxiliary Facilities
Under the Standard Industrial Classification (SIC)
system, an auxiliary facility was defined as one
that supported another covered establishment's
activities (e.g., research and development
laboratories, warehouses, and storage facilities).
An auxiliary facility could assume the SIC code of
another covered establishment if its primary
function was to service that other covered
establishment's operations. The North American
Industry Classification System (NAICS), that
replaces the SIC system for TRI reporting, does
not recognize the concept of auxiliary facilities
and assigns NAICS codes to all establishments
based on economic activity. In its rulemaking,
"Toxic Chemical Release Reporting Using North
American Industry Classification System," the
TRI Program has adopted NAICS for TRI
reporting and also the NAICS treatment of former
"auxiliary facilities" as entities with their own
distinct NAICS code.
B.2.b. Multi-establishment Facilities
Your facility may include multiple establishments
that have different NAICS codes. A multi-
establishment facility is a facility that consists of
two or more distinct and separate economic units.
If your facility is a multi-establishment facility,
calculate the value added of the products
produced, shipped, or services provided from each
establishment within the facility and then use the
following rule to determine if your facility meets
the NAICS code criterion:
• If the total value added of the products
produced, shipped, or services provided at
establishments with covered NAICS codes is
greater than 50 percent of the value added of
the entire facility's products and services, the
entire facility meets the NAICS code criterion.
• If any one establishment with a covered
NAICS code has a value added of services or
products shipped or produced that is greater
than any other establishment within the
facility (40 CFR Section 372.22(b)(3)) the
facility also meets the NAICS code criterion.
The value added of production or service
attributable to a particular establishment may be
isolated by subtracting the product value obtained
from other establishments within the same facility
from the total product or service value of the
facility. This procedure eliminates the potential for
"double counting" production and services in
situations where establishments are engaged in
sequential production or service activities at a
single facility.
Examples include:
• A facility in coating, engraving and allied
services has two establishments. The first
establishment, a general automotive repair
service, is in NAICS code 811113 (SIC 7537),
which is not a covered NAICS code. However,
the second establishment, a metal paint shop is
in NAICS code 332812 (SIC 3479, which is a
covered NAICS code). The metal paint shop
paints the parts received from general
automotive repair service. The facility
determines the product is worth $500/unit as
received from the general automotive repair
service (in non-covered NAICS code 811113)
and the value of the product is $1500/unit after
processing by the metal paint shop (in covered
NAICS code 332812). The value added by the
metal paint shop is obtained by subtracting the
value of the products from the general
automotive repair service from that of the
value of the products of the metal paint shop.
(In this example, the value added =
$l,500/unit - $500/unit = $l,000/unit.) The
value added ($l,000/unit) by the establishment
in NAICS code 332812 is more than 50
percent of the product value. Therefore, the
facility's primary NAICS code is 332812,
which is a covered NAICS code.
• A food processing establishment in a facility
processes crops grown at the facility in a
separate establishment. To determine the value
added of the products of each establishment
the facility could first determine the value of
the crops grown at the agricultural
establishment, and then calculate the
contribution of the food processing
establishment by subtracting the crop value
from the total value of the product shipped
from the processing establishment (value of
product shipped from processing - crop value
= value of processing establishment).
A covered multi-establishment facility must make
EPCRA Section 313 chemical threshold
determinations and, if required, must report all
relevant information about releases and other
waste management activities, and source reduction
activities associated with an EPCRA Section 313
chemical for the entire facility, even from
10
Toxics Release Inventory Reporting Forms and Instructions
-------
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
establishments that are not in covered NAICS
codes. EPA realizes, however, that certain
establishments in a multi-establishment facility
can be, for all practical purposes, separate and
distinct business units. Therefore, while threshold
determinations must be made for the entire
facility, individual establishments which compose
the entire facility may report their individual
releases and other waste management activities
separately. However, the total releases and other
waste management quantities for the entire facility
must be represented by the sum of the releases and
other quantities managed as waste reported by
each of the separate establishments.
B.2.c. Property Owners
You are not required to report if you merely own
real estate on which a facility covered by this rule
is located; that is, you have no other business
interest in the operation of that facility (e.g., your
company owns an industrial park). The operator of
that facility, however, is subject to reporting
requirements.
B.3 Activity Determination
B.3.a. Definitions of Manufacture,
Process, and Otherwise Use
Manufacture: The term "manufacture" means to
produce, prepare, compound, or import an EPCRA
Section 313 chemical. (See Part II, Section 3.1 of
these instructions for further clarification.)
Import is defined as causing the EPCRA Section
313 chemical to be imported into the customs
territory of the United States. If you order an
EPCRA Section 313 chemical (or a mixture
containing the chemical) from a foreign supplier,
then you have imported the chemical when that
shipment arrives at your facility directly from a
source outside of the United States. By ordering
the chemical, you have caused it to be imported,
even though you may have used an import
brokerage firm as an agent to obtain the EPCRA
Section 313 chemical.
Do Not Overlook Coincidental Manufacture
The term "manufacture" also includes
coincidental production of an EPCRA Section 313
chemical (e.g., as a byproduct or impurity) as a
result of the manufacture, processing, otherwise
use or disposal of another chemical or mixture of
chemicals. In the case of coincidental production
of an impurity (i.e., an EPCRA Section 313
chemical that remains in the product that is
distributed in commerce), the de minimis
exemption, discussed in Section B.3.c of these
instructions, applies. The de minimis exemption
does not apply to byproducts (e.g., an EPCRA
Section 313 chemical that is separated from a
process stream and further processed or disposed).
Certain EPCRA Section 313 chemicals may be
manufactured as a result of wastewater treatment
or other treatment processes. For example,
neutralization of wastewater containing nitric acid
can result in the coincidental manufacture of a
nitrate compound (solution), reportable as a
member of the nitrate compounds category.
Process: The term "process" means the
preparation of a listed EPCRA Section 313
chemical, after its manufacture, for distribution in
commerce. Processing is usually the incorporation
of an EPCRA Section 313 chemical into a product
(see Part II, Section 3.2 of these instructions for
further clarification). However, a facility may
process an impurity that already exists in a raw
material by distributing that impurity in
commerce. Processing includes preparation of the
EPCRA Section 313 chemicals in the same
physical state or chemical form as that received by
your facility, or preparation that produces a change
in physical state or chemical form. The term also
applies to the processing of a mixture or other
trade name product (see Section B.4.b of these
instructions) that contains a listed EPCRA Section
313 chemical as one component.
Otherwise Use: The term "otherwise use" means
any use of an EPCRA Section 313 chemical,
including an EPCRA Section 313 chemical
contained in a mixture or other trade name product
or waste, that is not covered by the terms
manufacture or process. Otherwise use of an
EPCRA Section 313 chemical does not include
disposal, stabilization (without subsequent
distribution in commerce), or treatment for
destruction unless:
(1) The EPCRA Section 313 chemical that was
disposed, stabilized, or treated for destruction was
received from off-site for the purposes of further
waste management;
Or
Toxics Release Inventory Reporting Forms and Instructions
11
-------
313 chemical where no repackaging of the
(2) The EPCRA Section 313 chemical that was EPCRA Section 313 chemical occurs does not
disposed, stabilized, or treated for destruction was constitute an otherwise use or processing of the
manufactured as a result of waste management EPCRA Section 313 chemical. (See 62 FR 23846
activities on materials received from off-site for and Part II, Section 3.3 of these instructions for
the purposes of waste management activities. further clarification).
Relabeling or redistributing of the EPCRA Section
Example 1: Coincidental Manufacture
Q Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system
to neutralize an acidic wastewater stream containing nitric acid. The reaction of ammonia and
nitric acid produces a solution of ammonium nitrate. Ammonium nitrate (solution) is reportable
under the nitrate compounds category and is manufactured as a byproduct. If the ammonium
nitrate is produced in a quantity that exceeds the 25,000-pound manufacturing threshold, the
facility must report under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise used and 10 percent of the total aqueous
ammonia would be counted towards the 10,000-pound otherwise use threshold. Reports for
releases of ammonia must also include 10 percent of the total aqueous ammonia from the
solution of ammonium nitrate (see the qualifier for the ammonia listing).
Q As another example, combustion of coal or other fuel in boilers/furnaces can result in the
coincidental manufacture of metal category compounds and sulfuric acid (acid aerosols),
hydrochloric acid (acid aerosols), and hydrogen fluoride.
12 Toxics Release Inventory Reporting Forms and Instructions
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 2: Typical Process and Manufacture Activities
G Your company receives toluene, an EPCRA Section 313 chemical, from another facility, and
reacts the toluene with air to form benzoic acid, which the company distributes in commerce.
Your company processes toluene and manufactures and processes benzoic acid. Benzoic acid,
however, is not an EPCRA Section 313 chemical and thus does not trigger reporting
requirements.
G Your facility combines toluene purchased from a supplier with various materials to form paint
which it then sells. Your facility processes toluene.
G Your company receives a nickel compound (nickel compounds is a listed EPCRA Section 313
chemical category) as a bulk solid and performs various size-reduction operations (e.g.,
grinding) before packaging the compound in 50-pound bags, which the company sells. Your
company processes the nickel compound.
G Your company receives a prepared mixture of resin and chopped fiber to be used in the
injection molding of plastic products. The resin contains a listed EPCRA Section 313 chemical
that becomes incorporated into the plastic, which the company distributes in commerce. Your
facility processes the EPCRA Section 313 chemical.
G In the combustion of coal or oil, metal category compounds may be produced from either the
parent metal or a metal compound contained in the coal or oil. If a metal undergoes a change of
valence, a metal compound is considered to be manufactured. For example, during the
combustion process copper in valence state zero changes to copper in valence state +2 in a
compound such as copper (II) oxide (CuO). Furthermore, a metallic compound could be
transformed to another metallic compound without a change in valency (e.g., copper (II)
chloride (CuC12) is transformed to copper (II) oxide (CuO)). The transformation to a new
compound by combustion without a change in valence state is also considered to be
"manufactured" for purposes of EPCRA Section 313.
Example 3: Typical Otherwise Use Activities
G When your facility cleans equipment with toluene, you are otherwise using toluene. Your
facility also separates two components of a mixture by dissolving one component in toluene,
and subsequently recovers the toluene from the process for reuse or disposal. Your facility
otherwise uses toluene.
G A covered facility receives a waste containing 12,000 pounds of Chemical A, a non-PBT
EPCRA Section 313 chemical, from off-site. The facility treats the waste, destroying Chemical
A and in the treatment process manufactures 10,500 pounds of Chemical B, another non-PBT
EPCRA Section 313 chemical. Chemical B is disposed on-site. Since the waste containing
Chemical A was received from off-site for the purpose of waste management, the amount of
Chemical A must be included in the otherwise use threshold determination for Chemical A. The
otherwise use threshold for a non-PBT chemical is 10,000 pounds and since the amount of
Chemical A exceeds this threshold, all releases and other waste management activities for
Chemical A must be reported. Chemical B was manufactured in the treatment of a waste
received from off-site. The facility disposed of Chemical B on-site. Since Chemical B was
generated from waste received from off-site for treatment for destruction, disposal, or
stabilization, the disposal of Chemical B is considered to be an otherwise use. Thus, the amount
of Chemical B must be considered in the otherwise use threshold determination. Thus, the
reporting threshold for Chemical B has also been exceeded and all releases and other waste
Toxics Release Inventory Reporting Forms and Instructions 13
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management activities for Chemical B must be reported.
B.3.b. Persistent Bioaccumulative
Toxic (PBT) Chemicals and
Chemical Categories Overview
On October 29, 1999, EPA published a final rule
(64 FR 58666) adding certain chemicals and
chemical categories to the EPCRA Section 313 list
of toxic chemicals and lowering the reporting
threshold for persistent bioaccumulative toxic
(PBT) chemicals. In addition, on January 17, 2001
EPA published a final rule (66 FR 4500) that
classified lead and lead compounds as PBT
chemicals and lowered their reporting thresholds.
The lower reporting thresholds for lead applies to
all lead except when lead is contained in a
stainless steel, brass or bronze alloy.
Dioxin and dioxin-like compounds, lead
compounds, mercury compounds and polycyclic
aromatic compounds (PACs) are the four PBT
chemical categories with lower reporting
thresholds. The 17 members of the dioxin and
dioxin-like compounds category and the 21
members of the PACs category are listed in Table
He of these instructions. The dioxin and dioxin-
like compounds category has the qualifier,
"Manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacturing of that
chemical."
EPA has added six individual chemicals to the
EPCRA Section 313 list of toxic chemicals that
also had their thresholds lowered:
benzo(g,h,i)perylene, benzo(j ,k)fluorene
(fluoranthene), 3 -methylcholanthrene,
octachlorostyrene, pentachlorobenzene, and
tetrabromobisphenol A (TBBPA).
Benzo(j,k)fluorene and 3-methylcholanthrene
were added as members of the polycyclic aromatic
compounds (PACs) chemical category.
EPA lowered the reporting thresholds for PBT
chemicals to either 100 pounds, 10 pounds, or in
the case of the dioxin and dioxin-like compounds
chemical category, to 0.1 grams. The table at the
beginning of Section B.4 of these instructions lists
the applicable manufacture, process, and otherwise
use thresholds for the listed PBT chemicals.
EPA eliminated the de minimis exemption for all
PBT chemicals (except lead when contained in
stainless steel, brass or bronze alloy). However,
this action does not affect the applicability of the
de minimis exemption to the supplier notification
requirements (40 CFR Section 372.45(d)(l)). In
addition, PBT chemicals are ineligible for range
reporting for on-site releases and transfers off-site
for further waste management. This will not affect
the applicability of range reporting of the
maximum amount on-site as required by EPCRA
Section 313(g).
All releases and other waste management
quantities greater than 0.1 pounds of a PBT
chemical (except the dioxin and dioxin like
compounds chemical category) should be reported
at a level of precision supported by the accuracy of
the underlying data and estimation techniques on
which the estimate is based. If a facility's release
or other waste management estimates support
reporting an amount that is more precise than
whole numbers, then the more precise amount
should be reported.
For the dioxin and dioxin-like compounds
chemical category, which has a reporting threshold
of 0.1 grams, facilities need only report all release
and other waste management quantities greater
than 100 micrograms (i.e., 0.0001 grams).
Notwithstanding the numeric precision used when
determining reporting eligibility thresholds,
facilities should report on the Form R to the level
of accuracy that their data supports, up to seven
digits to the right of the decimal. EPA's reporting
software and data management systems support
data precision to seven digits to the right of the
decimal. If a facility has information on the
individual members of the dioxin and dioxin-like
compounds category they will also need to file a
Form R Schedule 1 (see instructions in Section D).
Lead and Lead Compounds
Beginning January 1, 2001, lead and lead
compounds are classified as PBT chemicals and
are subject to the lower manufacturing, processing
and otherwise use threshold of 100 pounds.
However, when lead is contained in stainless steel,
brass, or bronze alloys it remains subject to the
higher 25,000 pound manufacturing and
processing thresholds and the 10,000 pound
otherwise use threshold. Listed below are some
important guidelines to use when calculating
14
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
threshold and release and other waste management
quantities for lead and lead compounds:
1) quantities of lead not contained in
stainless steel, brass or bronze alloy are applied to
both the 100 pound threshold and the
25,000/10,000 pound thresholds;
2) quantities of lead that are contained in
stainless steel, brass or bronze alloys are only
applied toward the 25,000/10,000 pound
thresholds;
3) a facility may take the de minimis
exemption for those quantities of lead in stainless
steel, brass, or bronze alloys that meet the de
minimis standard (e.g., manufactured as an
impurity). Accordingly, the de minimis exemption
may be considered for quantities of lead in
stainless steel, brass, or bronze alloys but it may
not be considered for lead not in stainless steel,
brass, or bronze alloys;
4) If a facility exceeds the 100-pound
threshold for lead other than in stainless steel,
brass, or bronze alloys, the facility may not apply
Form A eligibility for non-PBTs, range reporting
in Sections 5 and 6 of the Form R or the use of
whole numbers and 2 significant digits to any of
the lead they report though they may be eligible
for Form A using the PBT eligibility criteria. If a
facility that exceeds the 25,000/10,000 pound
threshold for lead in stainless steel, brass, or
bronze alloy without tripping the 100-pound
threshold for non-alloyed lead, the facility may
consider the Form A requirements for non-PBTs,
range reporting in Sections 5 and 6 of the Form R,
and the use of whole numbers and 2 significant
digits.
B.3.c. Activity Exemptions
Otherwise Use Exemptions. Certain otherwise
uses of listed EPCRA Section 313 chemicals are
specifically exempted:
• Otherwise use as a structural component of the
facility;
• Otherwise use in routine janitorial or facility
grounds maintenance;
• Personal uses by employees or other persons;
• Otherwise use of products containing EPCRA
Section 313 chemicals for the purpose of
maintaining motor vehicles operated by the
facility; and
• Otherwise use of EPCRA Section 313
chemicals contained in intake water (used for
processing or non contact cooling) or in intake
air (used either as compressed air or for
combustion).
The exemption of an EPCRA Section 313
chemical otherwise used 1) as a structural
component of the facility; or 2) in routine
janitorial or facility grounds maintenance; or 3) for
personal use by an employee cannot be taken for
activities involving process related equipment.
Articles Exemption. EPCRA Section 313
chemicals contained in articles that are processed
or otherwise used at a covered facility are exempt
from threshold determinations and release and
other waste management calculations. The
exemption applies when the facility receives the
article from another facility or when the facility
produces the article itself. The exemption applies
only to the quantity of EPCRA Section 313
chemical present in the article. If the EPCRA
Section 313 chemical is manufactured (including
imported), processed, or otherwise used at the
covered facility other than as part of the article, in
excess of an applicable threshold quantity, the
facility is required to report that use of a chemical
(40 CFR Section372.38(b)). For an EPCRA
Section 313 chemical in an item to be exempt as
part of the article, the item must meet all the
following criteria in the EPCRA Section 313
article definition; that is, it must be a
manufactured item (1) which is formed to a
specific shape or design during manufacture, (2)
which has end use functions dependent in whole or
in part upon its shape or design during end use,
and (3) which does not release a toxic chemical
under normal conditions of processing or use of
the item at the facility.
If the processing or otherwise use of all like items
results in a total release of 0.5 pound or less of an
EPCRA Section 313 chemical in a reporting year
to any environmental medium, EPA will allow this
release to be rounded to zero, and the
manufactured items retain their article status. The
0.5 pound threshold does not apply to each
individual article, but applies to the sum of all
releases from processing or otherwise use of all
like articles. If all the releases of like articles over
Toxics Release Inventory Reporting Forms and Instructions
15
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a reporting year are completely captured and
recycled/reused on-site or off-site, those items
retain their article status. Any amount that is
released and is not recycled/reused will count
toward the 0.5 pound per year cut off value.
The articles exemption applies to the normal
processing or use of articles. This exemption does
not apply to the manufacture of the article.
EPCRA Section 313 chemicals incorporated into
articles produced at a facility must be factored into
threshold determinations and release and other
waste management calculations.
If, in the course of processing or use, an item
retains its initial thickness or diameter, in whole or
in part, it meets the first part (i.e., it must be a
manufactured item which is formed to a specific
shape or design during manufacture) of the article
definition. If the item's basic dimensional
characteristics are totally altered during processing
or otherwise use, the item does not meet the first
part of the definition. An example of items that do
not meet the definition would be items that are
cold extruded, such as lead ingots, which are
formed into wire or rods. On the other hand,
cutting a manufactured item into pieces that are
recognizable as the article would not change the
original dimensions as long as the diameter or the
thickness of the item remained the same; the
articles exemption would continue to apply. Metal
wire may be bent and sheet metal may be cut,
punched, stamped, or pressed without losing their
article status as long as the diameter of the wire or
tubing or the thickness of the sheet is not totally
changed.
What constitutes a release of an EPCRA Section
313 chemical is important since processing or
otherwise use of articles that result in a release to
the environment (or more than 0.5 pounds) negate
the article status and precludes eligibility for the
exemption. Cutting, grinding, melting, or other
processing of manufactured items could result in a
release of an EPCRA Section 313 chemical during
normal conditions of processing or otherwise use
and therefore negate the exemption as articles.
Example 4: Articles Exemption
Q Nickel that is incorporated into a brass doorknob is processed to manufacture the brass
doorknob, and therefore must be counted toward threshold determinations and release and other
waste management calculations. However, the use of the brass doorknobs elsewhere in the
facility does not have to be counted. Disposal of the brass doorknob after its use does not
constitute a "release;" thus, the brass doorknob remains an article.
Q If an item used in the facility is fragmented, the item is still an article if those fragments being
discarded remain identifiable as the article (e.g., recognizable pieces of a cylinder, pieces of
wire). For instance, an eight-foot piece of wire is cut into two four-foot pieces of wire, without
releasing any EPCRA Section 313 chemicals. Each four-foot piece is identifiable as a piece of
wire; therefore, the article status for these pieces of wire remains intact.
Q EPCRA Section 313 chemicals received in the form of pellets are not articles because the pellet
form is simply a convenient form for further processing of the material.
De Minimis Exemption. The de minimis
exemption allows facilities to disregard certain
minimal concentrations of non-PBT chemicals
in mixtures or other trade name products when
making threshold determinations and release and
other waste management calculations. The de
minimis exemption does not apply to the
manufacture of an EPCRA Section 313 chemical
except if that EPCRA Section 313 chemical is
manufactured as an impurity and remains in the
product distributed in commerce, or if the
EPCRA Section 313 chemical is imported below
the appropriate de minimis level. The de minimis
exemption does not apply to a byproduct
manufactured coincidentally as a result of
manufacturing, processing, otherwise use, or any
waste management activities. The de minimis
exemption does not apply to any PBT chemical
(except lead when it is contained in stainless
steel, brass or bronze alloy) or PBT chemical
category. A list of PBT chemicals may be found
in Section B.4 of these instructions.
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
When determining whether the de minimis
exemption applies to an EPCRA Section 313
chemical, the owner/operator must consider the
concentration of the non-PBT EPCRA Section
313 chemical in mixtures and other trade name
products. If the non-PBT EPCRA Section 313
chemical in a mixture or other trade name
product is manufactured as an impurity,
imported, processed, or otherwise used and is
below the appropriate de minimis concentration
level, then the quantity of the non-PBT EPCRA
Section 313 chemical in that mixture or other
trade name product does not have to be applied
to threshold determinations nor included in
release or other waste management
determinations. If a non-PBT EPCRA Section
313 chemical in a mixture or other trade name
product is below the appropriate de minimis
level, all releases and other waste management
activities associated with the EPCRA Section
313 chemical in that mixture or other trade name
product are exempt from EPCRA Section 313
reporting. It is possible to meet an activity (e.g.,
processing) threshold for an EPCRA Section
313 chemical on a facility wide basis, but not be
required to calculate releases or other waste
management quantities associated with a
particular process because that process involves
only mixtures or other trade name products
containing the non-PBT EPCRA Section 313
chemical below the de minimis level.
EPA interprets the de minimis exemption such
that once a non-PBT EPCRA Section 313
chemical concentration is at or above the
appropriate de minimis level in the mixture or
other trade name product threshold
determinations and release and other waste
management calculations must be made, even if
that chemical later falls below the de minimis
level in the same mixture or other trade name
product. Thus, EPA considers reportable all
releases and other quantities managed as waste
that occur after the de minimis level has been
met or exceeded. If an EPCRA Section 313
chemical in a mixture or other trade name
product at or above de minimis is brought on-
site, the de minimis exemption never applies.
De minimis levels for non-PBT EPCRA Section
313 chemicals and chemical categories are set at
concentration levels of either 1 percent or 0.1
percent; PBT chemicals and chemical categories
do not have de minimis levels with regard to this
exemption. The 0.1 percent de minimis levels are
dictated by determinations made by the National
Toxicology Program (NTP) in its Annual Report
on Carcinogens, the International Agency for
Research and Cancer (IARC) in its Monographs,
or 29 CFR part 1910, subpart Z. Therefore, once
a non-PBT chemical's status under NTP, IARC,
or 29 CFR part 1910, subpart Z indicates that the
chemical is a carcinogen or potential carcinogen,
the reporting facility may disregard levels of the
chemical below the 0.1 percent de minimis
concentration provided that the other criteria for
the de minimis exemption are met. De minimis
levels for chemical categories apply to the total
concentration of all chemicals in the category
within a mixture, not the concentration of each
individual category member within the mixture.
Toxics Release Inventory Reporting Forms and Instructions
17
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Example 5: De Minimis Applications to Process and Otherwise Use Scenarios for Non-PBT
Chemicals
There are many cases in which the de minimis "limit" is crossed or recrossed by non-PBT chemicals
within a process or otherwise use scenario. The following examples are meant to illustrate these complex
reporting scenarios.
Increasing Concentration To or Above De Minimis Levels During Processing for Non-PBT
Chemicals
A manufacturing facility receives toluene that contains chlorobenzene at a concentration below its de
minimis limit. Through distillation, the chlorobenzene content in process streams is increased over the de
minimis concentration of 1 percent. From the point at which the chlorobenzene concentration equals 1
percent in process streams, the amount present must be factored into threshold determinations and release
and other waste management estimates. The facility does not need to consider the amount of
chlorobenzene in the raw material when below de minimis levels, i.e., prior to distillation to 1 percent,
when making threshold determinations. The facility does not have to report emissions of chlorobenzene
from storage tanks or any other equipment associated with that specific process where the chlorobenzene
content is less than 1 percent.
Fluctuating Concentration During Processing for Non-PBT Chemicals
A manufacturer produces an ink product that contains toluene, an EPCRA Section 313 chemical, below
the de minimis level. The process used causes the percentage of toluene in the mixture to fluctuate: it rises
above the de minimis level for a time but drops below the level as the process winds down. The facility
must consider the chemical toward threshold determinations from the point at which it first equals the de
minimis limit. Once the de minimis limit has been met the exemption cannot be taken.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
Concentration Ranges Straddling the De
Minimis Value
The de minimis exemption applies to the
processing or otherwise use of a non-PBT
EPCRA Section 313 chemical in a mixture.
Threshold determinations and release and other
waste management calculations begin at the
point where the chemical meets or exceeds the
de minimis level. If a non-PBT EPCRA Section
313 chemical is present in a mixture at a
concentration below the de minimis level, this
quantity of the substance does not have to be
included for threshold determinations, release
and other waste management reporting, or
supplier notification requirements. The
exemption will apply as long as the mixture
containing de minimis amounts of a non-PBT
EPCRA Section 313 chemical never equals or
goes above the de minimis limit.
There may be instances in which the
concentration of a non-PBT chemical is given as
a range straddling the de minimis limit. Example
6 illustrates how the de minimis exemption
should be applied in such a scenario.
De Minimis Application in the Manufacture
of the Listed Chemical in a Mixture
The de minimis exemption generally does not
apply to the manufacturing of an EPCRA
Section 313 chemical. However, the de minimis
exemption may apply to mixtures and other
trade name products containing non-PBT
EPCRA Section 313 chemicals that are imported
into the United States. (See Example 5.)
The exemption also applies to non-PBT EPCRA
Section 313 chemicals that are manufactured as
impurities that remain in the product distributed
in commerce below the de minimis levels. The
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
amount remaining in the product is exempt from an EPCRA Section 313 chemical that is
threshold determinations. If the chemical is manufactured in a waste stream must be
separated from the final product, it cannot considered toward threshold determinations and
qualify for the exemption. Any amount that is release and other waste management
separated, or is separate, from the product, is calculations and accounted for on Form R even
considered a byproduct and is subject to if that chemical is manufactured below the de
threshold determinations and release and other minimis level.
waste management calculations. Any amount of
Example 6: Concentration Ranges Straddling the De Minimis Value
D A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25 percent manganese.
Manganese is eligible for the de minimis exemption at concentrations up to 1 percent. The amount of
mixture subject to reporting is the quantity containing manganese at or above the de minimis
concentration:
[(8,000,000) H (1.25% - 0.99%)] ) (1.25% + 0.25%)
The average concentration of manganese that is not exempt (above the de minimis} is:
(1.25%+1.00%)) (2)
'(8,000,000X1.25%-0.99%)'
x
'(l.25%+ 1.00%)'
= 23,400pounds
(l.25%-0.25%)
Therefore, the amount of manganese that is subject to threshold determination and release and other waste
management estimates is:
= 23,400 pounds manganese (which is below the processing threshold for manganese)
In this scenario, because the facility's information pertaining to manganese was available to two decimal
places, 0.99 was used to determine the amount below the de minimis concentrations. If the information
was available to one decimal place, 0.9 should be used, as in the scenario below.
D As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is
processed. The MSDS states the mixture contains 0.2 percent to 1.2 percent manganese. The amount of
mixture subject to reporting (at or above de minimis limit) is:
[(8,000,000) H (1.2% - 0.9%)] ) (1.2% - 0.2%)
The average concentration of manganese that is not exempt (at or above de minimis limit) is:
(1.2%+1.0%)) (2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other
waste management estimates is:
= 26,400 pounds
'(8,000,OOOXl.2% - 0.9%)1 I"(l.2% + 1.0%)'
(l.2%-0.2%) ][ (2)
= 26,400 pounds manganese (which is above the processing threshold for manganese)
Toxics Release Inventory Reporting Forms and Instructions 19
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Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture
Manufacture as a Product Impurity
Toluene 2,4 diisocyanate reacts with trace amounts of water to form trace quantities of 2,4-
diaminotoluene. The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 2,4-
diaminotoluene. The 2,4 diaminotoluene would not be subject to EPCRA Section 313 reporting nor
would supplier notification be required because the concentration of 2,4- diaminotoluene is below its de
minimis limit of 0.1 percent in the product.
Manufacture as a Commercial Byproduct and Impurity
Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation
to a concentration of less than 150 ppm (0.0150 percent) remaining in the carbon tetrachloride. The
separated chloroform at 90 percent concentration is sold as a byproduct. Chloroform is subject to a 0.1
percent (1000 ppm) de minimis limit. Any amount of chloroform manufactured and separated as
byproduct must be included in threshold determinations because EPA does not interpret the de minimis
exemption to apply to the manufacture of a chemical as a byproduct. Releases of chloroform prior to and
during purification of the carbon tetrachloride must be reported. The de minimis exemption can, however,
be applied to the chloroform remaining in the carbon tetrachloride as an impurity. Because the
concentration of chloroform remaining in the carbon tetrachloride is below the de minimis limit, this
quantity of chloroform is exempt from threshold determinations, release and other waste management
reporting, and supplier notification.
Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a reaction byproduct during the production of
phthalic anhydride. The formaldehyde is separated from the phthalic anhydride as a waste gas and burned,
leaving no formaldehyde in the phthalic anhydride. The amount of formaldehyde produced and removed
must be included in threshold determinations and release and other waste management estimates even if
the formaldehyde were present below the de minimis level in the process stream where it was
manufactured or in the waste stream to which it was separated because EPA does not interpret mixtures
and trade name products to includes wastes.
The de minimis exemption also does not apply to
situations where a toxic chemical in waste is
diluted to below the de minimis level.
Laboratory Activities Exemption. EPCRA
Section 313 chemicals that are manufactured,
processed, or otherwise used in a laboratory at a
covered facility under the direct supervision of a
technically qualified individual do not have to be
considered for threshold determinations and
release and other waste management calculations.
However, pilot plant scale and specialty chemical
production does not qualify for this laboratory
activities exemption, nor does the use of EPCRA
Section 313 chemicals for laboratory support
activities, such as the use of chemicals for
equipment maintenance.
Coal Extraction Activities Exemption. If an
EPCRA Section 313 chemical is manufactured,
processed, or otherwise used in extraction by
facilities in NAICS codes 212111, 212112 and
212113, a person is not required to consider the
quantity of the EPCRA Section 313 chemical so
manufactured, processed, or otherwise used when
considering threshold determinations and release
and other waste management calculations (see
Example 8). Reclamation activities occurring
simultaneously with coal extraction activities (e.g.,
cast blasting) are included in the exemption.
However, otherwise use of ash, waste rock, or
fertilizer for reclamation purposes are not
considered part of extraction; non-exempt amounts
of EPCRA Section 313 chemicals contained in
these materials must be considered toward
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How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
threshold determinations and release and other
waste management calculations.
Metal Mining Overburden Exemption. If an
EPCRA Section 313 chemical that is a constituent
of overburden is processed or otherwise used by
facilities in NAICS codes 212221, 212222,
212231, 212234, and 212299, a person is not
required to consider the quantity of the EPCRA
Section 313 chemical so processed or otherwise
used when considering threshold determinations
and release and other waste management
calculations.
For purposes of EPCRA Section 313 reporting,
overburden is the unconsolidated material that
overlies a deposit of useful material or ore. It does
not include any portion of the ore or waste rock.
Example 8: Coal mining extraction activities
Included among these are explosives for
blasting operations, solvents, lubricants, and
fuels for extraction related equipment
maintenance and use, as well as overburden
and mineral deposits. The EPCRA Section 313
chemicals contained in these materials are
exempt from threshold determinations and
release and other waste management
calculations, when manufactured, processed or
otherwise used during extraction activities at
coal mines.
B.4 Threshold Determinations
EPCRA Section 313 reporting is required if
threshold quantities are exceeded. Separate
thresholds apply to the amount of the EPCRA
Section 313 chemical that is manufactured,
processed or otherwise used.
You must submit a report for any EPCRA Section
313 chemical that is not listed as a PBT chemical
and which is manufactured or processed at your
facility in excess of the following threshold:
• 25,000 pounds per toxic chemical or category
over the calendar year.
• You must submit a report for any EPCRA
Section 313 chemical which is not listed as a
PBT chemical and that is otherwise used at
your facility in excess of 10,000 pounds per
toxic chemical or category over the calendar
year.
You must submit a report for any EPCRA Section
313 chemical that is listed as a PBT chemical and
which is manufactured, processed or otherwise
used at your facility above the designated
threshold for that chemical.
The PBT chemical names, CAS numbers and their
reporting thresholds are listed in the table below.
See Table He of these instructions for lists of
individual members of the dioxin and dioxin-like
compounds chemical category and the polycyclic
aromatic compounds chemical category.
Toxics Release Inventory Reporting Forms and Instructions
21
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Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and
the processing or
otherwise use of dioxin
and dioxin-like
compounds category if
the dioxin and dioxin-
like compounds are
present as
contaminants in a
chemical and if they
were created during
the manufacturing of
that chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead (this lower
threshold does not
apply to lead when it is
contained in stainless
steel, brass or bronze
alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Fob/chlorinated
biphenyls (PCBs)
Poly cyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439.97-6
N458
72-43-5
29082-74-4
40487-42-1
608-93-5
1336-36-3
N590
79-94-7
Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0. 1 gram
10
10
10
100
100
10
10
100
10
100
10
10
100
100
A
Toxaphene
Trifluralin
8001-35-2
1582-09-8
10
100
B.4.a. How to Determine if Your
Facility Has Exceeded
Thresholds
To determine whether your facility has exceeded
an EPCRA Section 313 reporting threshold,
compare quantities of EPCRA Section 313
chemicals that you manufacture, process, or
otherwise use to the respective thresholds for those
activities. A worksheet is provided in Figure 2A to
assist facilities in determining whether they exceed
any of the reporting thresholds for non-PBT
chemicals; Figures 2B-D provide worksheets for
PBT chemicals. This worksheet also provides a
format for maintaining reporting facility records.
Use of this worksheet is not required and the
completed worksheet(s) should not accompany
Form R reports submitted to EPA and the state.
Complete the appropriate worksheet for each
EPCRA Section 313 chemical or chemical
category. (The worksheets can be found at the end
of section B.4.) Base your threshold determination
for EPCRA Section 313 chemicals with qualifiers
only on the quantity of the EPCRA Section 313
chemical satisfying the qualifier.
Use of the worksheets is divided into three steps:
• Step 1 allows you to record the gross amount
of the EPCRA Section 313 chemical or
chemical category involved in activities
throughout the facility. Pure forms as well as
the amounts of the EPCRA Section 313
chemical or chemical category present in
mixtures or other trade name products must be
considered. The types of activity (i.e.,
manufacturing, processing, or otherwise
using) for which the EPCRA Section 313
chemical is used must be identified because
separate thresholds apply to each of these
activities. A record of the information
source(s) used should be kept. Possible
information sources include purchase records,
inventory data, and calculations by a process
engineer. The data collected in Step 1 will be
totaled for each activity to identify the overall
amount of the EPCRA Section 313 chemical
or chemical category manufactured (including
imported), processed, or otherwise used.
22
Toxics Release Inventory Reporting Forms and Instructions
-------
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
• Step 2 allows you to identify uses of the
EPCRA Section 313 chemical or chemical
category that were included in Step 1 but are
exempt under EPCRA Section 313. Do not
include in Step 2 exempt quantities of the
EPCRA Section 313 chemical not included in
the calculations in Step 1. For example, if
Freon contained in the building's air
conditioners was not reported in Step 1, you
would not include the amount as exempt in
Step 2. Step 2 is intended for use when a
quantity or use of the EPCRA Section 313
chemical is exempt while other quantities
require reporting. Note the type of exemption
for future reference. Also identify, if
applicable, the fraction or percentage of the
EPCRA Section 313 chemical present that is
exempt. Add the amounts in each activity to
obtain a subtotal for exempted amounts of the
EPCRA Section 313 chemical or chemical
categories at the facility.
• Step 3 involves subtracting the result of Step 2
from the results of Step 1 for each activity.
Compare this net sum to the applicable
activity threshold. If the threshold is exceeded
for any of the three activities, a facility must
submit a Form R for that EPCRA Section 313
chemical or chemical category. Do not sum
quantities of the EPCRA Section 313 chemical
that are manufactured, processed, and
otherwise used at your facility, because each
of these activities requires a separate threshold
determination. For example, if in a calendar
year you processed 20,000 pounds of a non-
PBT EPCRA Section 313 chemical and you
otherwise used 6,000 pounds of that same
chemical, your facility has not exceeded any
applicable threshold and thus is not required to
report for that chemical.
Worksheets should be retained to document your
determination for reporting or not reporting, but
should not be submitted with the report.
You must submit a report if you exceed any
threshold for any EPCRA Section 313 chemical or
chemical category. For example, if your facility
processes 22,000 pounds of a non-PBT EPCRA
Section 313 chemical and also otherwise uses
16,000 pounds of that same chemical, it has
exceeded the otherwise use threshold (10,000
pounds for a non-PBT chemical) and your facility
must report even though it did not exceed the
process threshold (25,000 pounds for a non-PBT
chemical). In preparing your reports, you must
consider all non-exempted activities and all
releases and other waste management quantities of
the EPCRA Section 313 chemical from your
facility, not just releases and other waste
management quantities from the otherwise use
activity.
Also note that threshold determinations are based
upon the actual amounts of an EPCRA Section
313 chemical manufactured, processed, or
otherwise used over the course of the calendar
year. The threshold determination may not relate
to the amount of an EPCRA Section 313 chemical
brought on-site during the calendar year. For
example, if a stockpile of 100,000 pounds of a
non-PBT EPCRA Section 313 chemical is present
on-site but only 20,000 pounds of that chemical is
applied to a process, only the 20,000 pounds
processed is counted toward a threshold
determination, not the entire 100,000 pounds of
the stockpile.
B.4.b. Threshold Determinations for
On-Site Reuse Operations
Threshold determinations of EPCRA Section 313
chemicals that are reused at the facility are based
only on the amount of the EPCRA Section 313
chemical that is added during the year, not the
total volume in the system. For example, a facility
operates a refrigeration unit that contains 15,000
pounds of anhydrous ammonia at the beginning of
the year. The system is charged with 2,000 pounds
of anhydrous ammonia during the year. The
facility has therefore "otherwise used" only 2,000
pounds of anhydrous ammonia, a non-PBT
EPCRA Section 313 chemical, which is below the
otherwise use threshold for anhydrous ammonia
and is not required to report (unless there are other
"otherwise use" activities of ammonia, that when
taken together, exceed the reporting threshold). If,
however, the whole refrigeration unit was
recharged with 15,000 pounds of anhydrous
ammonia during the year, then the facility would
have exceeded the otherwise use threshold, and
would be required to report.
This does not apply to EPCRA Section 313
chemicals "recycled" or "reused" off-site and
returned to a facility. Such EPCRA Section 313
chemicals returned to a facility are treated as the
equivalent of newly purchased material for
Toxics Release Inventory Reporting Forms and Instructions
23
-------
purposes of EPCRA Section 313 threshold
determinations.
B.4.c. Threshold Determinations for
Ammonia
The listing for ammonia includes the modifier
"includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts
and other sources; 10 percent of total aqueous
ammonia is reportable under this listing." The
qualifier for ammonia means that anhydrous forms
of ammonia are 100 percent reportable and
aqueous forms are limited to 10 percent of total
aqueous ammonia. Therefore, when determining
threshold quantities, 100 percent of anhydrous
ammonia is included but only 10 percent of total
aqueous ammonia is included. If any ammonia
evaporates from aqueous ammonia solutions, 100
percent of the evaporated ammonia is included in
threshold determinations.
For example, if a facility processes aqueous
ammonia, it has processed 100 percent of the
aqueous ammonia in that solution. If the ammonia
remains in solution, then 10 percent of the total
aqueous ammonia is counted towards the
threshold. If there are any evaporative losses of
anhydrous ammonia, then 100 percent of those
losses must be counted towards the processing
threshold. If the manufacturing, processing, or
otherwise use threshold for the ammonia listing is
exceeded, the facility must report 100 percent of
these evaporative losses in Sections 5 and 8 of the
Form R.
B.4.d. Threshold Determinations for
Chemical Categories
A number of chemical compound categories are
subject to reporting. See Table He for a listing of
these EPCRA Section 313 chemical categories.
When preparing threshold determinations for one
of these EPCRA Section 313 chemical categories,
all individual members of a category that are
manufactured, processed, or otherwise used must
be counted. Where generic names are used at a
facility, threshold determinations should be based
on CAS numbers. For example, Poly-Solv EB
does not appear among the reportable chemicals in
Table Ha or lib but its CAS number indicates
Poly-Solv EB is a synonym for ethylene glycol
mono-n-butyl ether, a member of the certain
glycol ethers chemical category (code N230). For
chemical compound categories, threshold
determinations must be made separately for each
of the three activities. Do not include in these
threshold determinations for a category any
chemicals that are also individually listed EPCRA
Section 313 chemicals (see Table Ha or lib).
Individually listed EPCRA Section 313 chemicals
are subject to their own individual threshold
determination.
Organic Compounds
For the organic compound categories, you are
required to account for the entire weight of all
compounds within a specific compound category
(e.g., glycol ethers) at the facility for BOTH the
threshold determination and release and other
waste management estimates.
Metal Category Compounds
Threshold determinations for metal category
compounds present a special case. If, for example,
your facility processes several different nickel
compounds, base your threshold determination on
the total weight of all nickel compounds
processed. However, if your facility processes
both the "parent" metal (nickel) as well as one or
more nickel compounds, you must make threshold
determinations for both nickel (CAS number
7440-02-0) and nickel compounds (chemical
category code N495) because they are separately
listed EPCRA Section 313 chemicals. If your
facility exceeds thresholds for both the parent
metal and compounds of that same metal, EPA
allows you to file one combined report (e.g., one
report for nickel compounds, including nickel)
because the release information you will report in
connection with metal category compounds will be
the total pounds of the metal released. If you file
one combined report, you should put the name of
the metal compound category on the Form R. In
the example above, the facility that exceeded
reporting thresholds for both the nickel and nickel
compounds chemical category could submit a
single Form R for the nickel compounds chemical
category, which would contain release and other
waste management information for both nickel and
nickel compounds. Do not put both names on the
Form R.
The case of metal category compounds involving
more than one metal should be noted. Some metal
category compounds may contain more than one
listed metal. For example, lead chromate is both a
lead compound and a chromium compound. In
such cases, if applicable thresholds are exceeded,
you are required to file two separate reports, one
24
Toxics Release Inventory Reporting Forms and Instructions
-------
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
for lead compounds and one for chromium
compounds. Apply the total weight of the lead
chromate to the threshold determinations for both
lead compounds and chromium compounds.
(Note: Only the quantity of each parent metal
released or otherwise managed as waste, not the
quantity of the compound, would be reported on
the appropriate sections of both Form Rs. See
B.5.)
Nitrate Compounds (water dissociable;
reportable only when in aqueous solution)
For the category nitrate compounds (water
dissociable; reportable only when in aqueous
solution), the entire weight of the nitrate
compound is counted in making threshold
determinations. A nitrate compound is covered by
this listing only when in water and only if
dissociated. If no information is available on the
identity of the type of nitrate that is manufactured,
processed or otherwise used, assume that the
nitrate compound exists as sodium nitrate.
B.4.e Threshold Determination for
Persistent Bioaccumulative
Toxic (PBT) Chemicals
There are two separate thresholds for EPCRA
Section 313 PBT chemicals; these thresholds are
set based on the chemicals' potential to persist and
bioaccumulate in the environment. The
manufacturing, processing and otherwise use
thresholds for PBT chemicals is 100 pounds, while
for the subset of PBTs chemicals that are highly
persistent and highly bioaccumulative, it is 10
pounds. One exception is the dioxin and dioxin-
like compounds chemical category. The threshold
for this category is 0.1 gram. The PBT chemicals,
their CAS numbers or chemical category code, and
their reporting thresholds are listed in a table in the
introductory section of B.4. See Table He of these
instructions for lists of individual members of the
dioxin and dioxin-like compounds chemical
category and the polycyclic aromatic compounds
(PACs) chemical category.
B.4.f. Mixtures and Other Trade
Name Products
EPCRA Section 313 chemicals contained in
mixtures and other trade name products must be
factored into threshold determinations and release
and other waste management calculations.
If your facility processed or otherwise used
mixtures or other trade name products during the
calendar year, you are required to use the best
readily available data (or reasonable estimates if
such data are not readily available) to determine
whether the toxic chemicals in a mixture meet or
exceed the de minimis concentration and,
therefore, whether they must be included in
threshold determinations and release and other
waste management calculations. If you know that
a mixture or other trade name product contains a
specific EPCRA Section 313 chemical, combine
the amount of the EPCRA Section 313 chemical in
the mixture or other trade name product with other
amounts of the same EPCRA Section 313
chemical processed or otherwise used at your
facility for threshold determinations and release
and other waste management calculations. If you
know that a mixture contains an EPCRA Section
313 chemical but it is present below the de
minimis level, you do not have to consider the
amount of the EPCRA Section 313 chemical
present in that mixture for purposes of threshold
determinations and release and other waste
management calculations. PBT chemicals are not
eligible for the de minimis exemption except lead
when it is contained in stainless steel, brass or
bronze alloy.
Observe the following guidelines in estimating
concentrations of EPCRA Section 313 chemicals
in mixtures when only limited information is
available:
• If you only know the upper bound
concentration, you must use it for threshold
determinations (40 CFR Section372.30(b)(ii)).
• If you know the lower and upper bound
concentrations of an EPCRA Section 313
chemical in a mixture, EPA recommends you
use the midpoint of these two concentrations
for threshold determinations.
• If you know only the lower bound
concentration, EPA recommends you subtract
out the percentages of any other known
components to determine a reasonable upper
bound concentration, and then determine a
midpoint.
• If you have no information other than the
lower bound concentration, EPA recommends
Toxics Release Inventory Reporting Forms and Instructions
25
-------
you calculate a midpoint assuming an upper
bound concentration of 100 percent.
• In cases where you only have a concentration
range available, EPA recommends you use the
midpoint of the range extremes.
B.5 Release and Other Waste
Management Determinations
for Metals, Metal Category
Compounds, and Nitrate
Compounds
Metal Category Compounds
Although the complete weight of the metal
category compounds must be used in threshold
determinations for the metal compounds category,
only the weight of the metal portion of the metal
category compound must be considered for release
and other waste management determinations.
Remember that for metal category compounds that
consist of more than one metal, release and other
waste management reporting must be based on the
weight of each metal, provided that the appropriate
thresholds have been exceeded.
Metals and Metal Category Compounds
For compounds within the metal compound
categories, only the metal portion of the metal
category compound must be considered in
determining release and other waste management
quantities for the metal category compounds.
Therefore, if thresholds are separately exceeded
for both the "parent" metal and its compounds,
EPA allows you to file a combined Form R for the
"parent" metal and its category compounds. This
Form R would contain all of the release and other
waste management information for both the
"parent" metal and metal portion of the related
metal category compounds. For example, you
exceed thresholds for chromium. You also exceed
thresholds for chromium compounds. Instead of
filing two Form Rs you can file one combined
Form R. This Form R would contain information
on quantities of chromium released or otherwise
managed as waste and the quantities of the
chromium portion of the chromium compounds
released or otherwise managed as waste. When
filing one combined Form R for an EPCRA
Section 313 metal and metal compound category,
facilities should identify the chemical reported as
the metal compound category name and code in
Section 1 of the Form R. Note that this does not
apply to the Form A. See the section in these
instructions on the Form A. See Appendix B for
more information about reporting the release and
other waste management of metals and metal
compounds.
Nitrate Compounds (water dissociable;
reportable only in aqueous solution)
Although the complete weight of the nitrate
compound must be used for threshold
determinations for the nitrate compounds category
only the nitrate portion of the compound should be
used for release and other waste management
calculations.
26
Toxics Release Inventory Reporting Forms and Instructions
-------
How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
Example 9: Mixtures and Other Trade Name Products
Scenario #1: Your facility otherwise uses 12,000 pounds of an industrial solvent (Solvent X) for
equipment cleaning. The Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at
least 50 percent n-hexane, an EPCRA Section 313 chemical; however, it also states that the solvent
contains 20 percent non-hazardous surfactants. This is the only n-hexane-containing mixture used at the
facility.
EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
in solvent X exceeds the threshold for otherwise use.
1) Determine a reasonable maximum concentration for the EPCRA Section 313 chemical by
subtracting out the non-hazardous surfactants (i.e., 100% - 20% = 80%).
2) Determine the midpoint between the known minimum (50%) and the reasonable maximum
calculated above (i.e., (80% + 50%)/2 = 65%).
3) Multiply total weight of Solvent X otherwise used by 65% (0.65).
12,000 pounds x 0.65 = 7,800 pounds
4) Because the total amount of n-hexane otherwise used at the facility was less than the 10,000-pound
otherwise use threshold, the facility is not required to file a Form R for n-hexane.
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit boards.
The MSDS for the solvent lists only that Solvent Y contains at least 80 percent of an EPCRA Section 313
chemical that is only identified as chlorinated hydrocarbons.
EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
in the solvent exceeds the threshold for otherwise use.
1) Because the specific chemical is unknown, the Form R will be filed for "chlorinated hydrocarbons."
This name will be entered into Part II, Section 2.1, "Mixture Component Identity." (Note: Because
your supplier is claiming the EPCRA Section 313 chemical identity a trade secret, you do not have
to file substantiation forms.)
2) The upper bound limit is assumed to be 100 percent and the lower bound limit is known to be 80
percent. Using this information, the specific concentration is estimated to be 90 percent (i.e., the
mid-point between upper and lower limits).
(100% + 80%)/2 = 90%
3) The total weight of Solvent Y is multiplied by 90 percent (0.90) when calculating for thresholds.
15,000x0.90 = 13,500
4) Because the total amount of chlorinated hydrocarbons exceeds the 10,000-pound otherwise use
threshold, you must file a Form R for this chemical.
Toxics Release Inventory Reporting Forms and Instructions 27
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C. Instructions for
Completing TRI Form R
Parti. Facility Identification
Information
Section 1. Reporting Year
The reporting year is the calendar year to which
the reported information applies, not the year in
which you are submitting the report. Information
for the 2009 reporting year must be submitted on
or before July 1,2010.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section
313 chemical identified on Page 2 a
trade secret?
Answer this question only after you have
completed the rest of the report. The specific
identity of the EPCRA Section 313 chemical being
reported in Part II, Section 1 may be designated as
a trade secret. If you are making a trade secret
claim, mark "yes" and proceed to Section 2.2.
Only check "yes" if you manufacture, process, or
otherwise use the EPCRA Section 313 chemical
whose identity is a trade secret. (See Section A.3
of these instructions for specific information on
trade secrecy claims.) If you checked "no,"
proceed to Section 3; do not answer Section 2.2.
D See last year's Reporting Forms and
Instructions.
2.2 If "yes" in 2.1, is this copy sanitized or
unsanitized?
Answer this question only after you have
completed the rest of the report. Check "sanitized"
if this copy of the report is the public version that
does not contain the EPCRA Section 313 chemical
identity but does contain a generic name that is
structurally descriptive in its place, and if you
have claimed the EPCRA Section 313 chemical
identity trade secret in Part I, Section 2.1.
Otherwise, check "unsanitized."
Section 3. Certification
The certification statement must be signed by a
senior official with management responsibility for
the person (or persons) completing the form. A
senior management official must certify the
accuracy and completeness of the information
reported on the form by signing and dating the
certification statement. Each report must contain
an original signature. You should print or type the
name and title of the person who signs the
statement in the space provided. This certification
statement applies to all the information supplied
on the form and should be signed only after the
form has been completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI
Facility Identification Number
Enter the full name that the facility presents to the
public and its customers in doing business (e.g.,
the name that appears on invoices, signs, and other
official business documents). Do not use a
nickname for the facility (e.g., Main Street Plant)
unless that is the legal name of the facility under
which it does business. Also enter the street
address, mailing address, city, county, state, and
zip code in the space provided. Do not use a post
office box number as the street address. The street
address provided must be the location where the
EPCRA Section 313 chemicals are manufactured,
processed, or otherwise used. If your mailing
address and street address are the same, you
should enter NA in the space for the mailing
address.
If your facility is not in a county, put the name of
your city, district (for example, District of
Columbia), or parish (if you are in Louisiana) in
the county block of the Form R and Form A as
well as in the county field of TRI-ME OR TRI-
MEweb. "NA" or "None" are not acceptable
entries.
If you have submitted a Form R or Form A for
previous reporting years, a TRI Facility
Identification Number has been assigned to your
facility. If you know your TRI Facility
Identification Number, you should complete
Section 4. If you do not know your TRI Facility
Identification Number, you should visit the TRI
web page at
http ://www. epa. gov/tri/contacts/contacts .htm for
more information or contact your Regional TRI
Program representative, or utilize Envirofacts on
the Web to look up the address or facility name
http://www.epa.gov/enviro. If your facility has
moved, do not enter your TRI Facility
Identification Number, enter "New Facility". If
32
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing TRI Form R
you are filing a separate Form R for each
establishment at your facility, you should use the
same TRI Facility Identification Number for each
establishment.
The TRI Facility Identification Number is
established by the first Form R submitted by a
facility at a particular location. Only a change in
address warrants filing as a new facility;
otherwise, the TRI Facility Identification Number
is retained by the facility even if the facility
changes name, ownership, production processes,
SIC or NAICS codes, etc. This identification
number will stay with this location. If a new
facility moves to this location it should use this
TRI Facility Identification Number.
Establishments of a facility that report separately
should use the TRI Facility Identification Number
of the facility.
You should enter "New Facility" in the space for
the TRI Facility Identification number if this is
your first submission.
4.2 Full or Partial Facility Indication
EPCRA Section 313 requires reports by
"facilities," which are defined as "all buildings,
equipment, structures, and other stationary items
which are located on a single site or on contiguous
or adjacent sites and which are owned or operated
by the same person (or by any person which
controls, is controlled by, or under common
control with such person). A facility may contain
more than one establishment."
EPCRA Section 313 defines establishment as "an
economic unit, generally at a single physical
location, where business is conducted or where
services or industrial operations are performed."
Under Section 372.30(c) of the reporting rule, you
may submit a separate Form R for each
establishment, or for groups of establishments in
your facility, provided all releases and other waste
management activities and source reduction
activities involving the EPCRA Section 313
chemical from the entire facility are reported. This
allows you the option of reporting separately on
the activities involving an EPCRA Section 313
chemical at each establishment, or group of
establishments (e.g., part of a covered facility),
rather than submitting a single Form R for that
EPCRA Section 313 chemical for the entire
facility. However, if an establishment or group of
establishments does not manufacture, process, or
otherwise use or release or otherwise manage as
waste an EPCRA Section 313 chemical, you do
not have to submit a report for that establishment
or group of establishments for that particular
chemical. (See also Section B.2.a of these
instructions.)
A covered facility must report all releases and
other waste management activities and source
reduction activities of an EPCRA Section 313
chemical if the facility meets a reporting threshold
for that EPCRA Section 313 chemical. Whether
submitting a report for the entire facility or
separate reports for the establishments, the
threshold determination must be made based on
the entire facility. Indicate in Section 4.2 whether
your report is for the entire covered facility as a
whole or for part of a covered facility (i.e., one or
more establishments).
Federal facilities and contractors at federal
facilities (GOCOs: Government-owned,
contractor-operated facilities) should check either
4.2c or 4.2d, but not both. Federal facilities should
check 4.2c, even if their TRI reports contain
release and other waste management information
from contractors located at the facility.
Contractors at federal facilities, which are required
by EPCRA Section 313 to file TRI reports
independently of the federal facility, should check
4.2d. This information is important to prevent
duplication of federal facility data. (See Appendix
A for further guidance on these instructions.)
4.3 Technical Contact
Enter the name and telephone number (including
area code) of a technical representative whom
EPA or state officials may contact for clarification
of the information reported on Form R. You
should also enter an email address for this person.
EPA encourages facilities to provide an email
address for its Technical Contact on their TRI
submissions because they will be able to receive
important program updates and email alerts
notifying them when their FDP has been updated
and is available on the FDP website. If the
technical contact does not have an email address
you should enter NA. This contact person does not
have to be the same person who prepares the
report or signs the certification statement and does
not necessarily need to be someone at the location
of the reporting facility. However, this person
Toxics Release Inventory Reporting Forms and Instructions
33
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should be familiar with the details of the report so
that he or she can answer questions about the
information provided.
your establishments have been assigned D&B
numbers, enter those numbers in Part I, section
4.6.
4.4
Public Contact
Enter the name and telephone number (including
area code) of a person who can respond to
questions from the public about the form. You
should also enter an e-mail address for this person.
If you choose to designate the same person as both
the Technical and the Public Contact, or you do
not have a Public Contact, you may enter "Same
as Section 4.3" in this space. This contact person
does not have to be the same person who prepares
the form or signs the Certification Statement and
does not necessarily need to be someone at the
location of the reporting facility.
4.5 North American Industry Classification
System (NAICS) Codes
The North American Industry Classification
System (NAICS) is the economic classification
system that replaces the 1987 SIC code system for
TRI Reporting beginning with the RY 2006
EPCRA Section 313 reporting (71 FR 32464).
Enter the appropriate six digit North American
Industry Classification System (NAICS) Code that
is the primary NAICS code for your facility in
Section 4.5(a). For Reporting Year 2008 and
beyond, use 2007 NAICS codes. Enter any other
applicable NAICS for your facility in 4.5 (b)-(f).
Table I lists the TRI-covered NAICS codes. If you
do not know your NAICS code, consult the 2007
NAICS Manual (see Section B.2 of these
instructions for ordering information) or check the
SIC to NAICS crosswalk tables at
http://www.census.gov
4.6 Dun & Bradstreet Number(s)
Enter the nine digit number assigned by Dun &
Bradstreet (D&B) for your facility or each
establishment within your facility. These numbers
code the facility for financial purposes. This
number may be available from your facility's
treasurer or financial officer. You can also obtain
the numbers from Dun & Bradstreet by calling 1-
888-814-1435, or by visiting this web site:
https://www.dnb.com/product/dlw/form cc4.htm.
If a facility does not subscribe to the D&B service,
a number can be obtained, toll free at 800 234-
3867 (8:00 AM to 6:00 PM, Local Time) or on the
Web at http://www.dnb.com. If none of your
establishments has been assigned a D&B number,
you should enter NA in box (a). If only some of
Section 5.
Parent Company
Information
You must provide information on your parent
company. For purposes of the Form R, a parent
company is defined as the highest level company,
located in the United States, that directly owns at
least 50 percent of the voting stock of your
company. If your facility is owned by a foreign
entity, enter NA in this space. Corporate names
should be treated as parent company names for
companies with multiple facility sites. For
example, the Bestchem Corporation is not owned
or controlled by any other corporation but has sites
throughout the country whose names begin with
Bestchem. In this case, Bestchem Corporation
should be listed as the parent company. Note that a
facility that is a 50:50 joint venture is its own
parent company. When a facility is owned by
more than one company and none of the facility
owners directly owns at least 50 percent of its
voting stock, the facility should provide the name
of the parent company of either the facility
operator or the owner with the largest ownership
interest in the facility. If neither the operator nor
this owner has a parent company, then the NA box
should be checked.
5.1 Name of Parent Company
Enter the name of the corporation or other
business entity that is your ultimate U.S. parent
company. If your facility has no parent company,
you should check the NA box.
5.2 Parent Company's Dun & Bradstreet
Number
Enter the D&B number for your ultimate U.S.
parent company, if applicable. The number may be
obtained from the treasurer or financial officer of
the company or by calling 1-888-814-1435, or by
visiting this web site:
https ://www.dnb.com/product/dlw/form cc4 .htm.
If your parent company does not have a D&B
number, you should check the NA box.
34
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Part II. Chemical Specific
Information
In Part II, you are to report on:
• The EPCRA Section 313 chemical being
reported;
• The general uses and activities involving the
EPCRA Section 313 chemical at your facility;
• On-site releases of the EPCRA Section 313
chemical from the facility to air, water, and
land;
• Quantities of the EPCRA Section 313
chemical transferred to off-site locations;
• Information for on-site and off-site disposal,
treatment, energy recovery, and recycling of
the EPCRA Section 313 chemical; and
• Source reduction activities.
Section 1. EPCRA Section 313
Chemical Identity
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS)
registry number in Section 1.1 exactly as it
appears in Table II of these instructions for the
chemical being reported. CAS numbers are cross-
referenced with an alphabetical list of chemical
names in Table II. If you are reporting one of the
EPCRA Section 313 chemical categories (e.g.,
chromium compounds), you should enter the
applicable category code in the CAS number
space. EPCRA Section 313 chemical category
codes are listed below and can also be found in
Table He and Appendix B.
EPCRA Section 313 Chemical Category Codes:
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable,
reportable only in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (CIO to C13)
N590 Polycyclic aromatic compounds (PACs)
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
If you are making a trade secret claim, you must
report the CAS number or category code on your
unsanitized Form R and unsanitized substantiation
form. Do not include the CAS number or category
code on your sanitized Form R or sanitized
substantiation form.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA Section 313
chemical or chemical category exactly as it
appears in Table II. If the EPCRA Section 313
chemical name is followed by a synonym in
parentheses, report the chemical by the name that
directly follows the CAS number (i.e., not the
synonym). If the EPCRA Section 313 chemical
identity is actually a product trade name (e.g.,
Dicofol), the 9th Collective Index name is listed
below it in brackets. You may report either name
in this case.
Do not list the name of a chemical that does not
appear in Table II, such as individual members of
an EPCRA Section 313 chemical category. For
example, if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category
code, N740.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form R and
unsanitized substantiation form. Do not report the
name of the EPCRA Section 313 chemical on your
Toxics Release Inventory Reporting Forms and Instructions
35
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sanitized Form R or sanitized substantiation form.
Include a generic name that is structurally
descriptive in Part II, Section 1.3 of your sanitized
Form R report.
EPA requests that the EPCRA Section 313
chemical, chemical category, or generic name also
be placed in the box marked "Toxic Chemical,
Category, or Generic Name" in the upper right-
hand corner on all pages of Form R. While this
space is not a required data element, providing this
information will help you in preparing a complete
Form R report.
1.3
Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form R. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to
seventy characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names
in Section 1.3; see Section 2 below.
In-house plant codes and other substitute names
that are not structurally descriptive of the EPCRA
Section 313 chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both sanitized
and unsanitized Form Rs, and the name must be
the same as that used on your substantiation forms.
Section 2. Mixture Component
Identity
Do not complete this section if you have
completed Section 1 of Part II. Report the generic
name provided to you by your supplier in this
section if your supplier is claiming the chemical
identity proprietary or trade secret. Do not answer
"yes" in Part I, Section 2.1 on Page 1 of the form
if you complete this section. You do not need to
supply trade secret substantiation forms for this
EPCRA Section 313 chemical because it is your
supplier who is claiming the chemical identity a
trade secret.
Example 10: Mixture Containing
Unidentified EPCRA Section 313
Chemical
Your facility uses 20,000 pounds of a
solvent that your supplier has told you
contains 80 percent "chlorinated aromatic,"
their generic name for a non-PBT EPCRA
Section 313 chemical subject to reporting
under EPCRA Section 313. You, therefore,
have used 16,000 pounds of some EPCRA
Section 313 chemical and that exceeds the
"otherwise use" threshold for a non-PBT
chemical. You would file a Form R and enter
the name "chlorinated aromatic" in the space
provided in Part II, Section 2.
2.1 Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this section
only if the following three conditions apply:
1.) You determine that the mixture
contains an EPCRA Section 313 chemical but the
only identity you have for that chemical is a
generic name;
2.) You know either the specific
concentration of that EPCRA Section 313
chemical component or a maximum or average
concentration level; and
3.) You multiply the concentration level
by the total annual amount of the whole mixture
processed or otherwise used and determine that
you meet the process or otherwise use threshold
for that single, generically identified mixture
component.
Section 3. Activities and Uses of the
EPCRA Section 313
Chemical at the Facility
Indicate whether the EPCRA Section 313
chemical is manufactured (including imported),
processed, or otherwise used at the facility and the
general nature of such activities and uses at the
facility during the calendar year (see Figure 3).
You are not required to report on Form R the
quantity manufactured, processed or otherwise
used. Report activities that take place only at your
facility, not activities that take place at other
facilities involving your products. You must check
all the boxes in this section that apply. Refer to the
36
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
definitions of "manufacture," "process," and and/or (b), and at least one of (c), (d), (e), and (f)
"otherwise use" in the general information section in Section 3.1.
of these instructions or Part 40, Section 372.3 of
the Code of Federal Regulations for additional
3.2
explanations.
3.1 Manufacture the EPCRA Section 313
Chemical
Persons who manufacture (including import) the
EPCRA Section 313 chemical must check at least
one of the following:
a. Produce — The EPCRA Section 313
chemical is produced at the facility.
b. Import — The EPCRA Section 313
chemical is imported by the facility into the
Customs Territory of the United States. (See
Section B.3.a of these instructions for
further clarification of import.)
And check at least one of the following:
c. For on-site use/processing — The EPCRA
Section 313 chemical is produced or
imported and then further processed or
otherwise used at the same facility. If you
check this block, generally you should also
check at least one item in Part II, Section 3.2
or 3.3.
d. For sale/distribution — The EPCRA
Section 313 chemical is produced or
imported specifically for sale or distribution
outside the manufacturing facility.
e. As a byproduct — The EPCRA Section 313
chemical is produced coincidentally during
the manufacture, processing, or otherwise
use of another chemical substance or
mixture and, following its production, is
separated from that other chemical
substance or mixture. EPCRA Section 313
chemicals produced as a result of waste
management are also considered byproducts.
f. As an impurity — The EPCRA Section 313
chemical is produced coincidentally as a
result of the manufacture, processing, or
otherwise use of another chemical but is not
separated and remains in the mixture or
other trade name product with that other
chemical.
In summary, if you are a manufacturer of the
EPCRA Section 313 chemical, you must check (a)
Process the EPCRA Section 313
Chemical
Persons who process the EPCRA Section 313
chemical must check at least one of the following:
a.
b.
c.
d.
e.
As a reactant — A natural or synthetic
EPCRA Section 313 chemical is used in
chemical reactions for the manufacture of
another chemical substance or of a product.
Includes but is not limited to, feedstocks, raw
materials, intermediates, and initiators.
As a formulation component — An EPCRA
Section 313 chemical is added to a product
(or product mixture) prior to further
distribution of the product that acts as a
performance enhancer during use of the
product. Examples of EPCRA Section 313
chemicals used in this capacity include, but
are not limited to, additives, dyes, reaction
diluents, initiators, solvents, inhibitors,
emulsifiers, surfactants, lubricants, flame
retardants, and rheological modifiers.
As an article component — An EPCRA
Section 313 chemical becomes an integral
component of an article distributed for
industrial, trade, or consumer use. One
example is the pigment components of paint
applied to a chair that is sold.
Repackaging — This consists of processing
or preparation of an EPCRA Section 313
chemical (or product mixture) for distribution
in commerce in a different form, state, or
quantity. This includes, but is not limited to,
the transfer of material from a bulk container,
such as a tank truck to smaller containers
such as cans or bottles.
As an impurity — The EPCRA Section 313
chemical is processed but is not separated
and remains in the mixture or other trade
name product with that/those other
chemical(s).
3.3
Otherwise Use the EPCRA Section 313
Chemical (non-incorporative activities)
Persons who otherwise use the EPCRA Section
313 chemical must check at least one of the
following:
Toxics Release Inventory Reporting Forms and Instructions
37
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As a chemical processing aid — An EPCRA
Section 313 chemical that is added to a
reaction mixture to aid in the manufacture or
synthesis of another chemical substance but
is not intended to remain in or become part of
the product or product mixture is otherwise
used as chemical processing aid. Examples of
such EPCRA Section 313 chemicals include,
but are not limited to, process solvents,
catalysts, inhibitors, initiators, reaction
terminators, and solution buffers.
As a manufacturing aid — An EPCRA
Section 313 chemical that aids the
manufacturing process but does not become
part of the resulting product and is not added
to the reaction mixture during the
manufacture or synthesis of another chemical
substance is otherwise used as a
manufacturing aid. Examples include, but are
not limited to, process lubricants,
metalworking fluids, coolants, refrigerants,
and hydraulic fluids.
Ancillary or other use — An EPCRA
Section 313 chemical that is used at a facility
for purposes other than aiding chemical
processing or manufacturing as described
above is otherwise used as an ancillary or
other use. Examples include, but are not
limited to, cleaners, degreasers, lubricants,
fuels, EPCRA Section 313 chemicals used
for treating wastes, and EPCRA Section 313
chemicals used to treat water at the facility.
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
334-88-3
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only ore name exactly as it appears on the Section 313 list.)
Diazomethane
1.3
Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
(If there are any numbers in boxes 1-17, then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution should
be reported in percentages and the total should equal 0 or 100%. If you do not have speciatson data available, check NA.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
NA
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a. X Produce b.
Import
If produce or import:
Foron-site use/processing
For sale/distribution
As a byproduct
As an impurity
X
As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
Figure 3. Reporting EPCRA Section 313 Chemicals
Section 4.
Maximum Amount of the
EPCRA Section 313
Chemical On-site at Any
Time during the Calendar
Year
For data element 4.1 of Part II, insert the code (see
codes below) that indicates the maximum quantity
of the EPCRA Section 313 chemical (e.g., in storage
tanks, process vessels, on-site shipping containers,
or in wastes generated) at your facility at any time
during the calendar year. If the EPCRA Section 313
chemical was present at several locations within
your facility, use the maximum total amount present
at the entire facility at any one time. While range
reporting is not allowed for PBT chemicals
elsewhere on the Form R, range reporting for PBT
chemicals is allowed for the Maximum Amount On-
site.
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Instructions for Completing Part II of EPA Form R
Example 11: Manufacturing and Processing
Activities of EPCRA Section 313 Chemicals
In the two examples below, it is assumed that the
threshold quantities for manufacture, process, or
otherwise use (25,000 pounds, 25,000 pounds, and
10,000 pounds, respectively for non-PBT
chemicals; 100 pounds for certain PBT chemicals;
10 pounds for highly persistent, highly
bioaccumulative toxic chemicals; and 0.1 grams
for the PBT chemical category comprised of dioxin
and dioxin-like compounds) have been exceeded
and the reporting of EPCRA Section 313
chemicals is therefore required.
1. Your facility manufactures diazomethane. Fifty
percent is sold as a product, thus it is processed.
The remaining fifty percent is reacted with alpha-
naphthylamine, forming N-methyl-alpha-
naphthylamine and also producing nitrogen gas.
D Your company manufactures diazomethane,
an EPCRA Section 313 chemical, both for
sale/ distribution as a commercial product
and for on-site use/processing as a feedstock
in the N-methyl-alpha-naphthylamine
production process. Because the
diazomethane is a reactant, it is also
processed. See Figure 3 for how this
information would be reported in Part II,
Section 3 of Form R.
D Your facility also processes alpha-
naphthylamine, as a reactant to produce N-
methyl-alpha-naphthylamine, a chemical not
on the EPCRA Section 313 list.
2. Your facility is a commercial distributor of
Missouri bituminous coal, which contains mercury
at 1.5 ppm (w:w). You should check the box on the
Form R at Part II, Section 3.2.e for processing
mercury as an impurity.
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From...
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
To...
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
If the EPCRA Section 313 chemical present at your
facility was part of a mixture or other trade name
product, determine the maximum quantity of the
EPCRA Section 313 chemical present at the facility
by calculating the weight percent of the EPCRA
Section 313 chemical only.
Do not include the weight of the entire mixture or
other trade name product. These data may be found
in the Tier II form your facility may have prepared
under Section 312 of EPCRA. See Part 40, Section
372.30(b) of the Code of Federal Regulations for
further information on how to calculate the weight
of the EPCRA Section 313 chemical in the mixture
or other trade name product. For EPCRA Section
313 chemical categories (e.g., nickel compounds),
include all chemical compounds in the category
when calculating the maximum amount, using the
entire weight of each compound. When reporting
for dioxin and dioxin-like compounds you should
convert the maximum amount from grams to pounds
before choosing the appropriate range code in
Section 4 of Part II.
Section 5. Quantity of the EPCRA
Section 313 Chemical
Entering Each
Environmental Medium On-
site
In Section 5, you must account for the total
aggregate on-site releases of the EPCRA Section
313 chemical to the environment from your facility
for the calendar year.
Toxics Release Inventory Reporting Forms and Instructions
39
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On-site releases to the environment include
emissions to the air, discharges to surface waters,
and releases to land and underground injection
wells.
For all toxic chemicals (except the dioxin and
dioxin-like compound category), do not enter the
values in Section 5 in gallons, tons, liters, or any
measure other than pounds. You must also enter the
values as whole numbers (do not use scientific
notation). Numbers following a decimal point are
not acceptable for toxic chemicals other than those
designated as PBT chemicals. For PBT chemicals,
facilities should report release and other waste
management quantities greater than 0.1 pound
(except the dioxin and dioxin-like compounds
category), provided the accuracy and the underlying
data on which the estimate is based supports this
level of precision.
For the dioxin and dioxin-like compounds category,
facilities should report at a level of precision
supported by the accuracy of the underlying data
and the estimation techniques on which the estimate
is based. For the dioxin and dioxin like compounds
chemical category, which has a reporting threshold
of 0.1 gram, facilities need only report all release
and other waste management quantities greater than
100 micrograms (i.e., 0.0001 grams). (See Example
12.) Notwithstanding the numeric precision used
when determining reporting eligibility thresholds,
facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA's reporting software
and data management systems support data
precision up to seven digits to the right of the
decimal.
Example 12: Reporting Dioxins and Dioxin-
Like Compounds
If the total quantity for Section 5.2 of the Form
R (i.e., stack or point air emissions) is 0.00005
grams or less, then zero can be entered. If the
total quantity is between 0.00005 and 0.0001
grams, then 0.0001 grams can be entered or the
actual number can be entered (e.g., 0.000075).
contained the EPCRA Section 313 chemical is not
directed to the relevant environmental medium, or if
leaks, spills and fugitive emissions cannot occur. If
the waste stream that contains or contained the
EPCRA Section 313 chemical is directed to the
environmental medium, or if leaks, spills or fugitive
emissions can occur, NA should not be used, even if
treatment or emission controls result in a release of
zero. If the annual aggregate release of that
chemical was equal to or less than 0.5 pound, the
value reported is zero (unless the chemical is a listed
PBT chemical).
For Section 5.1, NA generally is not applicable for
volatile organic compounds (VOCs). For Section
5.5.4, NA generally would not be applicable,
recognizing the possibility of accidental spills or
leaks of the EPCRA Section 313 chemical.
An example that illustrates the use of NA vs. a
numeric value (e.g., zero) would be nitric acid
involved in a facility's processing activities. If the
facility neutralizes the wastes containing nitric acid
to a pH of 6 or above, then the facility reports a
release of zero for the EPCRA Section 313
chemical, not NA. Another example is when the
facility has no underground injection well, in which
case NA should be entered in Part I, Section 4.10
and checked in Part II, Section 5.4.1 and 5.4.2 of
Form R. Also, if the facility does not landfill the
acidic waste, NA should be checked in Part II,
Section 5.5.1.B of Form R.
All releases of the EPCRA Section 313 chemical to
the air must be classified as either stack or fugitive
emissions, and included in the total quantity
reported for these releases in Sections 5.1 and 5.2.
Instructions for columns A, B, and C follow the
discussions of Sections 5.1 through 5.5.
5.1
Fugitive or Non-Point Air Emissions
NA vs. a Numeric Value (e.g., Zero). Generally,
NA is applicable if the waste stream that contains or
Report the total of all releases of the EPCRA
Section 313 chemical to the air that are not released
through stacks, vents, ducts, pipes, or any other
confined air stream. You must include (1) fugitive
equipment leaks from valves, pump seals, flanges,
compressors, sampling connections, open-ended
lines, etc.; (2) evaporative losses from surface
impoundments and spills; (3) releases from building
ventilation systems; and (4) any other fugitive or
non-point air emissions. Engineering estimates and
mass balance calculations (using purchase records,
inventories, engineering knowledge or process
specifications of the quantity of the EPCRA Section
313 chemical entering product, hazardous waste
40
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
manifests, or monitoring records) may be useful in
estimating fugitive emissions. You should check the
NA box in Section 5.1 if you do not engage in
activities that result in fugitive or non-point air
emissions of this listed toxic chemical. For VOCs,
NA generally would not be applicable.
5.2 Stack or Point Air Emissions
Report the total of all releases of the EPCRA
Section 313 chemical to the air that occur through
stacks, confined vents, ducts, pipes, or other
confined air streams. You must include storage tank
emissions. Air releases from air pollution control
equipment would generally fall in this category.
Monitoring data, engineering estimates, and mass
balance calculations may help you to complete this
section. You should check the NA box in Section
5.2 if there are no stack air activities involving the
waste stream that contains or contained the EPCRA
Section 313 chemical.
5.3 Discharges to Receiving Streams or
Water Bodies
In Section 5.3 you are to enter all the names of the
streams or water bodies to which your facility
directly discharges the EPCRA Section 313
chemical on which you are reporting. A total of
three spaces is provided on Page 2 of Form R. Enter
the name of each receiving stream or surface water
body to which the EPCRA Section 313 chemical
being reported is directly discharged. Report the
name of the receiving stream or water body as it
appears on the permit for the facility. If the stream is
not included in the NPDES permit or its name is not
identified in the NPDES permit, enter the name of
the off-site stream or water body by which it is
publicly known or enter the first publicly named
water body to which the receiving waters are a
tributary, if the receiving waters are unnamed. Do
not list a series of streams through which the
EPCRA Section 313 chemical flows. Be sure to
include all the receiving streams or water bodies that
receive stormwater runoff from your facility. Do not
enter names of streams to which off-site treatment
plants discharge. You should enter NA in Section
5.3.1 if there are no discharges to receiving streams
or water bodies of the waste stream that contains or
contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5).
Enter the total annual amount of the EPCRA Section
313 chemical released from all discharge points at
the facility to each receiving stream or water body.
Include process outfalls such as pipes and open
trenches, releases from on-site wastewater treatment
systems, and the contribution from stormwater
runoff, if applicable (see instructions for column C
below). Do not include discharges to a POTW or
other off-site wastewater treatment facilities in this
section. These off-site transfers must be reported in
Part II, Section 6 of Form R. Wastewater analyses
and flowmeter data may provide the quantities you
will need to complete this section.
Discharges of listed acids (e.g., hydrogen fluoride,
nitric acid) may be reported as zero if the discharges
have been neutralized to pH 6 or above. If
wastewater containing a listed acid is discharged
below pH 6, then releases of the acid must be
reported. In this case, pH measurements may be
used to estimate the amount of mineral acid
released.
5.4.1 Underground Injection On-Site to Class I
Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into Class I wells at the
facility. Chemical analyses, injection rate meters,
and RCRA Hazardous Waste Generator Reports are
good sources for obtaining data that will be useful in
completing this section. You should check the NA
box in Section 5.4.1 if you do not inject the waste
stream that contains or contained the EPCRA
Section 313 chemical into Class I underground
wells (See discussion of NA vs. a Numeric Value
(e.g., Zero) in the introduction of Section 5).
5.4.2 Underground Injection On-site to Class II-
V Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into wells at the facility
other than Class I wells. Chemical analyses and
injection rate meters are good sources for obtaining
data that will be useful in completing this section.
You should check the NA box in Section 5.4.2 if
you do not inject the waste stream that contains or
contained the EPCRA Section 313 chemical into
Class II-V underground wells (See discussion of NA
vs. a Numeric Value (e.g., Zero) in the introduction
of Section 5).
Toxics Release Inventory Reporting Forms and Instructions
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5.5 Disposal to Land On-site
Five predefined subcategories for reporting
quantities released to land within the boundaries of
the facility are provided. Do not report land disposal
at off-site locations in this section. Accident
histories and spill records may be useful (e.g.,
release notification reports required under Section
304 of EPCRA, Section 103 of CERCLA, and
accident histories required under
Sectionll2(r)(7)(B)(ii) of the Clean Air Act).
Where relevant, you should check the NA box in
sections 5.5.1 A through 5.5.3 if there are no
disposal activities for the waste stream that contains
or contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5). For 5.5.4, facilities
generally should report zero, recognizing the
potential for spills or leaks.
5.5.1A RCRA Subtitle C landfills
Enter the total amount of the EPCRA Section 313
chemical that was placed in RCRA Subtitle C
landfills. EPA has not required facilities to estimate
leaks from landfills because the amount of the
EPCRA Section 313 chemical has already been
reported as a release.
5.5. IB Other landfills
Enter the total amount of the EPCRA Section 313
chemical that was placed in landfills other than
RCRA Subtitle C landfills. EPA has not required
facilities to estimate leaks from landfills because the
amount of the EPCRA Section 313 chemical has
already been reported as a release.
5.5.2 Land treatment/application farming
Land treatment is a disposal method in which a
waste containing an EPCRA Section 313 chemical
is applied onto or incorporated into soil. While this
disposal method is considered a release to land, any
volatilization of EPCRA Section 313 chemicals into
the air occurring during the disposal operation must
not be included in this section but must be included
in the total fugitive air releases reported in Part II,
Section 5.1 of Form R.
Surface Impoundments
A surface impoundment is a natural topographic
depression, man-made excavation, or diked area
formed primarily of earthen materials (although
some may be lined with man-made materials), that
is designed to hold an accumulation of liquid wastes
or wastes containing free liquids. Examples of
surface impoundments are holding, settling, storage,
and elevation pits; ponds, and lagoons. If the pit,
pond, or lagoon is intended for storage or holding
without discharge, it would be considered to be a
surface impoundment used as a final disposal
method. A facility must determine, to the best of its
ability, the percentage of a volatile chemical, e.g.,
benzene, that is in waste sent to a surface
impoundment that evaporates during the reporting
year. The facility must report this as a fugitive air
emission in section 5.1. The balance should be
reported in either section 5.5.3A or 5.5.3B.
Quantities of the EPCRA Section 313 chemical
released to surface impoundments that are used
merely as part of a wastewater treatment process
generally should not be reported in this section.
However, if an impoundment accumulates sludges
containing the EPCRA Section 313 chemical, you
must include an estimate in this section unless the
sludges are removed and otherwise disposed (in
which case they must be reported under the
appropriate section of the form). For the purposes of
this reporting, storage tanks are not considered to be
a type of disposal and are not to be reported in this
section of Form R.
5.5.3A RCRA Subtitle C Surface Impoundments
Enter the total amount of the EPCRA Section 313
chemical that was placed in RCRA Subtitle C
surface impoundments.
5.5.3B Other Surface Impoundments
Enter the total amount of the EPCRA Section 313
chemical that was placed in surface impoundments
other than RCRA Subtitle C surface impoundments.
5.5.4 Oth er Disposal
Includes any amount of an EPCRA Section 313
chemical released to land that does not fit the
categories of landfills, land treatment, or surface
impoundment. This other disposal would include
any spills or leaks of EPCRA Section 313 chemicals
to land. For example, 2,000 pounds of benzene leaks
from an underground pipeline into the land at a
facility. Because the pipe was only a few feet from
the surface at the erupt point, 30 percent of the
benzene evaporates into the air. The 600 pounds
released to the air would be reported as a fugitive air
release (Part II, Section 5.1) and the remaining
1,400 pounds would be reported as a release to land,
other disposal (Part II, Section 5.5.4).
42
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Section 5 Column A: Total Release
Only on-site releases of the EPCRA Section 313
chemical to the environment for the calendar year
are to be reported in this section of Form R. The
total on-site releases from your facility do not
include transfers or shipments of the EPCRA
Section 313 chemical from your facility for sale or
distribution in commerce, or of wastes to other
facilities for disposal, treatment, energy recovery, or
recycling (see Part II, Section 6 of these
Instructions). Both routine releases, such as fugitive
air emissions, and accidental or non-routine
releases, such as chemical spills, must be included
in your estimate of the quantity released.
Releases of Less Than 1,000 Pounds. For total
annual releases or off-site transfers of an EPCRA
Section 313 chemical from the facility of less than
1,000 pounds, the amount may be reported either as
an estimate or by using the range codes that have
been developed (range reporting in section 5 does
not apply to PBT chemicals). The reporting range
codes to be used are:
Code
A
B
C
Range (pounds)
1-10
11-499
500-999
Do not enter a range code and an estimate in the
same box in column A. Total annual on-site releases
of an EPCRA Section 313 chemical from the facility
of less than 1 pound may be reported in one of
several ways. You should round the value to the
nearest pound. If the estimate is greater than 0.5
pound, you should either enter the range code "A"
for "1-10" or enter "1" in column A. If the release is
equal to or less than 0.5 pound, you may round to
zero and enter "0" in column A.
Note that total annual releases of 0.5 pound or less
from the processing or otherwise use of an article
maintain the article status of that item. Thus, if the
only releases you have are from processing an
article, and such releases are equal to or less than
0.5 pound per year, you are not required to submit a
report for that EPCRA Section 313 chemical. The
0.5-pound release determination does not apply to
just a single article. It applies to the cumulative
releases from the processing or otherwise use of the
same type of article (e.g., sheet metal or plastic film)
that occurs over the course of the reporting year.
Releases of 1,000 Pounds or More. For releases to
any medium that amount to 1,000 pounds or more
for the year, you must provide an estimate in pounds
per year in column A. Any estimate provided in
column A need not be reported to more than two
significant figures. This estimate should be in whole
numbers. Do not use decimal points.
Calculating On-Site Releases. To provide the
release information in column A, EPCRA Section
313(g)(2) requires a facility to use readily available
data (including monitoring data) collected pursuant
to other provisions of law, or, where such data are
not readily available, "reasonable estimates" of the
amounts involved. If available data (including
monitoring data) are known to be non-
representative, facilities must make reasonable
estimates using the best readily available
information.
Reasonable estimates of the amounts released
should be made using published emission factors,
material balance calculations, or engineering
calculations. You may not use emission factors or
calculations to estimate releases if more accurate
data are available.
No additional monitoring or measurement of the
quantities or concentrations of any EPCRA Section
313 chemical released into the environment, or of
the frequency of such releases, beyond that required
under other provisions of law or regulation or as
part of routine plant operations, is required for the
purpose of completing Form R.
You must estimate the quantity (in pounds) of the
EPCRA Section 313 chemical or chemical category
that is released annually to each environmental
medium on-site. Include only the quantity of the
EPCRA Section 313 chemical in this estimate. If the
EPCRA Section 313 chemical present at your
facility was part of a mixture or other trade name
product, calculate only the releases of the EPCRA
Section 313 chemical, not the other components of
the mixture or other trade name product. If you are
only able to estimate the releases of the mixture or
other trade name product as a whole, you should
assume that the release of the EPCRA Section 313
chemical is proportional to its concentration in the
mixture or other trade name product. See Part 40,
Section372.30(b) of the Code of Federal
Regulations for further information on how to
calculate the concentration and weight of the
Toxics Release Inventory Reporting Forms and Instructions
43
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EPCRA Section 313 chemical in the mixture or
other trade name product.
If you are reporting an EPCRA Section 313
chemical category listed in Table II of these
instructions rather than a specific EPCRA Section
313 chemical, you must combine the release data for
all chemicals in the EPCRA Section 313 chemical
category (e.g., all listed members of certain glycol
ethers or all listed members of chlorophenols) and
report the aggregate amount for that EPCRA
Section 313 chemical in that category separately.
For example, if your facility releases 3,000 pounds
per year of 2-chlorophenol, 4,000 pounds per year
of 3-chlorophenol, and 4,000 pounds per year of 4-
chlorophenol to air as fugitive emissions, you must
report that your facility releases 11,000 pounds per
year of chlorophenols to air as fugitive emissions in
Part II, Section 5.1.
For aqueous ammonia solutions, releases must be
reported based on 10 percent of total aqueous
ammonia. Ammonia evaporating from aqueous
ammonia solutions is considered to be anhydrous
ammonia; therefore, 100 percent of the anhydrous
ammonia should be reported if it is released to the
environment. For dissociable nitrate compounds,
release estimates should be based on the weight of
the nitrate only.
For metal category compounds (e.g., chromium
compounds), report releases of only the parent
metal. For example, a user of various inorganic
chromium salts would report the total chromium
released regardless of the chemical compound and
exclude any contribution to mass made by the other
portion of the compound.
Section 5 Column B: Basis of Estimate
For each release and otherwise managed waste
estimate (Sections 5 & 6), you are required to
indicate the principal method used to determine the
amount of release and otherwise managed waste
reported. You should enter a letter code identifying
the method that applies to the largest portion of the
total estimated release and otherwise managed waste
quantity.
The codes are as follows:
Ml Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical
C Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
El Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2 Estimate is based on-site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
For example, if 40 percent of stack emissions of the
reported EPCRA Section 313 chemical were derived
using source testing data, 30 percent by mass
balance, and 30 percent by published chemical-
specific emission factors, you should enter the code
letter "M2" for periodic or random emission
monitoring.
If the monitoring data, mass balance, or emission
factor used to estimate the release is not specific to
the EPCRA Section 313 chemical being reported,
the form should identify the estimate as based on
other methods of estimation (O).
If a mass balance calculation yields the flow rate of
a waste, but the quantity of reported EPCRA
Section 313 chemical in the waste is based on
solubility data, you should report "O" because
engineering calculations were used as the basis of
estimate of the quantity of the EPCRA Section 313
chemical in the waste.
If the concentration of the EPCRA Section 313
chemical in the waste was measured by continuous
emissions monitoring equipment and the flow rate
of the waste was determined by mass balance, then
the primary basis of the estimate should be
"continuous emission monitoring" (Ml). Even
though a mass balance calculation also contributed
to the estimate, "continuous emission monitoring"
should be indicated because monitoring data were
used to estimate the concentration of the chemical in
waste.
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Instructions for Completing Part II of EPA Form R
Mass balance (C) should only be indicated if it is
directly used to calculate the mass (weight) of
EPCRA Section 313 chemical released. Monitoring
data should be indicated as the basis of estimate
only if the EPCRA Section 313 chemical
concentration is measured in the waste. Monitoring
data should not be indicated, for example, if the
monitoring data relate to a concentration of the
EPCRA Section 313 chemical in other process
streams within the facility.
It is important to realize that the accuracy and
proficiency of release estimation will improve over
time. However, submitters are not required to use
new emission factors or estimation techniques to
revise previous Form R submissions.
Section 5 Column C: Percent from Stormwater
This column relates only to Section 5.3 - discharges
to receiving streams or water bodies. If your facility
has monitoring data on the amount of the EPCRA
Section 313 chemical in stormwater runoff
(including unchanneled runoff), you must include
that quantity of the EPCRA Section 313 chemical in
your water release in column A and indicate the
percentage of the total quantity (by weight) of the
EPCRA Section 313 chemical contributed by
stormwater in column C (Section 5.3C).
If your facility has monitoring data on the EPCRA
Section 313 chemical and an estimate of flow rate,
you must use these data to determine the percent
stormwater.
If you have monitored stormwater but did not detect
the EPCRA Section 313 chemical, enter zero in
column C. If your facility has no stormwater
monitoring data for the chemical, you should enter
NA in this space on the form.
If your facility does not have periodic measurements
of stormwater releases of the EPCRA Section 313
chemical, but has submitted chemical-specific
monitoring data in permit applications, then these
data must be used to calculate the percent
contribution from stormwater. One way to calculate
the flow rates from stormwater runoff is the
Rational Method. In this method, flow rates, Q, can
be estimated by multiplying the land area of the
facility, A, by the runoff coefficient, C, and then
multiplying that figure by the annual rainfall
intensity, I (i.e., Q = A*C*I). The rainfall intensity,
I, is specific to the geographical area of the country
where the facility is located, and may be obtained
from most standard engineering manuals for
hydrology. The flow rate, Q, will have volumetric
dimensions per unit time, and will have to be
converted to units of pounds per year. The runoff
coefficient represents the fraction of rainfall that
does not seep into the ground but runs off as
stormwater. The runoff coefficient is directly related
to how the land in the drainage area is used. (See
table below)
Description of Land Area Runoff Coefficient Description of Land Area Runoff Coefficient
Business
Downtown areas 0.70-0.95
Neighborhood areas 0.50-0.70
Industrial
Light areas 0.50-0.80
Heavy areas 0.60-0.90
Industrial
Railroad yard areas 0.20-0.40
Unimproved areas 0.10-0.30
Streets
Asphaltic 0.70-0.95
Concrete 0.80-0.95
Brick 0.70-0.85
Drives and walks 0.70-0.85
Roofs 0.75-0.95
Lawns: Sandy Soil
Flat, 2 percent 0.05-0.10
Average, 2-7 percent 0.10-0.15
Steep, 7 percent 0.15-0.20
Lawns: Heavy Soil
Flat, 2 percent 0.13-0.17
Average, 2-7 percent 0.18-0.22
Steep, 7 percent 0.25-0.35
You should choose the most appropriate runoff coefficient for your site or calculate a weighted-average
coefficient, which takes into account different types of land use at your facility:
Toxics Release Inventory Reporting Forms and Instructions
45
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Weighted-average runoff coefficient =
(Area 1 % of total)(Cl) + (Area 2 % of total)(C2) + (Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
where
Ci = runoff coefficient for a specific land use of Area i.
Example 13: Stormwater Runoff
Your facility is located in a semi-arid region of the United States that has an annual precipitation
(including snowfall) of 12 inches of rain. (Snowfall should be converted to the equivalent inches of rain;
assume one foot of snow is equivalent to one inch of rain.) The total area covered by your facility is 42
acres (about 170,000 square meters or 1,829,520 square feet). The area of your facility is 50 percent
unimproved area, 10 percent asphaltic streets, and 40 percent concrete pavement.
The total storm water runoff from your facility is therefore calculated as follows:
Land Use % Total Area
Unimproved area 50
Asphaltic streets 10
Concrete pavement 40
Runoff
Coefficient
0.20
0.85
0.90
Weighted-average runoff coefficient = [(50%) x (0.20)] + [(10%) x (0.85)] + [(40%) x (0.90)] = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = Stormwater runoff
(1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year
Total Stormwater runoff = 7,458,222 gallons/year
Your Stormwater monitoring data shows that the average concentration of zinc in the Stormwater runoff
from your facility from a biocide containing a zinc compound is 1.4 milligrams per liter. The total
amount of zinc discharged to surface water through the plant wastewater discharge (non-stormwater) is
250 pounds per year. The total amount of zinc discharged with Stormwater is:
(7,458,222 gallons stormwater)x(3.785 liters/gallon) = 28,229,370 liters Stormwater
(28,229,370 liters stormwater)x(1.4 mg zinc/liter) x 103 g/mg x (1/454) Ib/g = 87 Ib zinc.
The total amount of zinc discharged from all sources of your facility is:
250 pounds zinc from wastewater discharged
+87 pounds zinc from Stormwater runoff
337 pounds zinc total water discharged
The percentage of zinc discharge through Stormwater reported in section 5.3 column C on Form R is:
(87/337)xlOO% = 26%
Section 6. Transfers of the EPCRA
Section 313 Chemical in
Wastes to Off-Site Locations
You must report in this section the total annual
quantity of the EPCRA Section 313 chemical in
wastes sent to any off-site facility for the purposes
of disposal, treatment, energy recovery, or
recycling. Report the total amount of the EPCRA
Section 313 chemical transferred off-site after any
on-site waste treatment, recycling, or removal is
completed.
For all toxic chemicals (except the dioxin and
dioxin-like compounds category), do not enter the
values in Section 6 in gallons, tons, liters, or any
measure other than pounds. You must also enter the
values as whole numbers. Numbers following a
decimal point are not acceptable for toxic chemicals
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Instructions for Completing Part II of EPA Form R
other than those designated as PBT chemicals. For
PBT chemicals, facilities should report release and
other waste management quantities greater than 0.1
pound (except the dioxin and dioxin-like
compounds category) provided the accuracy and the
underlying data on which the estimate is based
supports this level of precision. For the dioxin and
dioxin-like compounds category, facilities should
report at a level of precision supported by the
accuracy of the underlying data and the estimation
techniques on which the estimate is based.
However, the smallest quantity that need be reported
on the Form R for the dioxin and dioxin-like
compounds category is 0.0001 grams (see Example
12). Notwithstanding the numeric precision used
when determining reporting eligibility thresholds,
facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA's reporting software
and data management systems support data
precision to seven digits to the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You must
enter a numeric value if you transfer an EPCRA
Section 313 chemical to a POTW or transfer wastes
containing that toxic chemical to other off-site
locations. If the aggregate amount transferred was
less than 0.5 pound, then you should enter zero
(unless the chemical is listed as a PBT chemical).
Also report zero for transfers of listed mineral acids
(i.e., hydrogen fluoride and nitric acid) if they have
been neutralized to a pH of 6 or above prior to
discharge to a POTW; do not check NA.
However, if you do not discharge wastewater
containing the reported EPCRA Section 313
chemical to a POTW, you should enter NA in the
box for the POTW's name in Section 6.1.B._ If you
do not ship or transfer wastes containing the
reported EPCRA Section 313 chemical to other off-
site locations, you should enter NA in the box for
the off-site location's EPA Identification Number in
Section 6.2._.
Important: You must number the boxes for
reporting the information for each POTW or other
off-site location in Sections 6.1 and 6.2. In the upper
left hand corner of each box, the section number is
either 6.1.B._. or 6.2._.
If you report a transfer of the listed EPCRA Section
313 chemical to one or more POTWs, you should
number the boxes in Section 6.1.B as 6.I.B.I,
6.1.B.2, etc. If you transfer the EPCRA Section 313
chemical to more than two POTWs, you should
photocopy Page 3 of Form R as many times as
necessary and then number the boxes consecutively
for each POTW. At the bottom of Part II Section 6.1
of the Form R you will find instructions for
indicating the total number of pages numbered "3"
that you are submitting as part of Form R, as well as
indicating the sequence of those pages. For
example, your facility transfers the reported EPCRA
Section 313 chemical in wastewaters to three
POTWs. You would photocopy Page 3 once,
indicate at the bottom of each Page 3 that there are a
total of two pages numbered "3" and then indicate
the first and second Page 3. The boxes for the two
POTWs on the first Page 3 should be numbered
6.I.B.I and 6.1.B.2, while the box for third POTW
on the second Page 3 should be numbered 6.I.B.3.
If you report a transfer of the EPCRA Section 313
chemical to one or more other off-site locations, you
should number the boxes in section 6.2 as 6.2.1,
6.2.2, etc. If you transfer the EPCRA Section 313
chemical to more than two other off-site locations,
you should photocopy Page 4 of Form R as many
times as necessary and then number the boxes
consecutively for each off-site location. At the
bottom of Page 4 you will find instructions for
indicating the total number of Page 4s that you are
submitting as part of the Form R as well as
indicating the sequence of those pages. For
example, your facility transfers the reported EPCRA
Section 313 chemical to three other off-site
locations. You should photocopy page 4 once,
indicate at the bottom of Section 6.2 on each Page 4
that there are a total of two Page 4s and then
indicate the first and second Page 4. The boxes for
the two off-site locations on the first Page 4 would
be numbered 6.2.1 and 6.2.2, while the box for the
third off-site location on the second Page 4 should
be numbered 6.2.3.
6.1 Discharges to Publicly Owned Treatment
Works
In Section 6.1.A, estimate the quantity of the
reported EPCRA Section 313 chemical transferred
to all POTWs and the basis upon which the estimate
was made. In Section 6.I.E., you should enter the
name and address for each POTW to which your
facility discharges or otherwise transfers wastewater
containing the reported EPCRA Section 313
chemical. The most common transfers of this type
will be conveyances of the toxic chemical in facility
wastewater through underground sewage pipes;
however, materials may also be trucked or
Toxics Release Inventory Reporting Forms and Instructions
47
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transferred via some other direct methods to a
POTW.
If you do not discharge wastewater containing the
reported EPCRA Section 313 chemical to a POTW,
enter NA in the box for the POTW's name in
Section 6.1.B._ (See discussion of NA vs. a
Numeric Value (e.g., Zero) in the introduction of
Section 6).
6.1.A.1 Total Transfers
Enter the total amount, in pounds, of the reported
EPCRA Section 313 chemical that is contained in
the wastewaters transferred to all POTWs. Do not
enter the total poundage of the wastewaters. If the
total amount transferred is less than 1,000 pounds,
you may report a range by entering the appropriate
range code (range reporting in section 6.I.A.I does
not apply to PBT chemicals). The following
reporting range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
6. LA. 2 Basis of Estimate
You must identify the basis for your estimate of the
total quantity of the reported EPCRA Section 313
chemical in the wastewater transferred to all
POTWs. You should enter one of the following
letter codes that applies to the method by which the
largest percentage of the estimate was derived.
Ml Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C Estimate is based on mass balance
calculations, such as calculation of the amount
of the EPCRA Section 313 chemical in
streams entering and leaving process
equipment.
El Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2 Estimate is based on-site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
If you transfer an EPCRA Section 313 chemical to
more than one POTW, you should report the basis
of estimate that was used to determine the largest
percentage of the EPCRA Section 313 chemical that
was transferred.
6.2
Transfers to Other Off-Site Locations
In Section 6.2 enter the EPA Identification Number,
name, and address for each off-site location to
which your facility ships or transfers wastes
containing the reported EPCRA Section 313
chemical for the purposes of disposal, treatment,
energy recovery, or recycling. Also estimate the
quantity of the reported EPCRA Section 313
chemical transferred and the basis upon which the
estimate was made. This would include any residual
chemicals in "empty" containers transferred off-site.
EPA expects that all containers (bags, totes, drums,
tank trucks, etc.) will have a small amount of
residual solids and/or liquids. Please see Example
14 for residue quantities left in drums and tanks
when emptied.
If appropriate, you must report multiple activities
for each off-site location. For example, if your
facility sends a reported EPCRA Section 313
chemical in a single waste stream to an off-site
location where some of the EPCRA Section 313
chemical is to be recycled while the remainder of
the quantity transferred is to be treated, you must
report both the waste treatment and recycle
activities, along with the quantity associated with
each activity.
If your facility transfers an EPCRA Section 313
chemical to an off-site location and that off-site
location performs more than four activities on that
chemical, provide the necessary information in Box
6.2.1 for the off-site facility and the first four
activities. Provide the information on the remainder
of the activities in Box 6.2.2 and provide again the
off-site facility identification and location
information.
48
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
If you do not ship or transfer wastes containing the
EPCRA Section 313 chemical to other off-site
locations, you should enter NA (See discussion of
NA vs. a Numeric Value (e.g., Zero) in the
introduction of Section 6) in the box for the off-site
location's EPA Identification Number (defined in 40
CFR 260.10 and therefore commonly referred to as
the RCRA ID Number). This number may be found
on the Uniform Hazardous Waste Manifest, which is
required by RCRA regulations. If you ship or
transfer wastes containing an EPCRA Section 313
chemical and the off-site location does not have an
EPA Identification Number (e.g., it does not accept
RCRA hazardous wastes) enter NA in the box for
the off-site location EPA Identification Number. If
you ship or transfer hazardous wastes containing an
EPCRA Section 313 chemical to a facility that
treats, stores, or disposes RCRA hazardous wastes,
make sure to include that facility's RCRA
Identification Number in the box for the off-site
location EPA Identification Number. This RCRA ID
is shown on the RCRA manifest that must
accompany the hazardous waste to the off-site
facility.
If you ship or transfer the reported EPCRA Section
313 chemical in wastes to another country, you do
not need to report a RCRA ID for that waste. You
should indicate NA in the RCRA ID field. Enter the
complete address of the non-U.S. facility in the off-
site address fields, the city in the city field, the non-
U.S. state or province in the county field, the postal
code in the zip code field, and the foreign country
code in the country field. The most commonly used
FIPs codes are listed in Table IV. To obtain a FIPS
code for a country not listed, contact the TRI
Information Center. There is nothing to enter in the
state field.
6.2a Column A: Total Transfers
For each off-site location, enter the total amount, in
pounds (in grams for dioxin and dioxin-like
compounds), of the EPCRA Section 313 chemical
that is contained in the waste transferred to that
location. Do not enter the total quantities of the
waste. If you do not ship or transfer wastes
containing the EPCRA Section 313 chemical to
other off-site locations, you should enter NA (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 6) in the box for the
off-site location's EPA Identification Number
(defined in 40 CFR 260.10 and therefore commonly
referred to as the RCRA ID Number).
If the total amount transferred is less than 1,000
pounds, you may report a range by entering the
appropriate range code (range reporting in section
6.2 does not apply to PBT chemicals). The
following reporting range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
Toxics Release Inventory Reporting Forms and Instructions
49
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Summary of Residue Quantities From Pilot-Scale Experimental Studya'b
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined
tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244
0.472
0.404
0.032
0.080
0.054
0.020
0.039
0.033
0.031
0.042
0.038
0.024
0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266
0.458
0.403
0.026
0.039
0.034
0.016
0.024
0.019
0.033
0.034
0.034
0.020
0.040
0.033
Motor Oile
1.97-2.23
2.06
1.70-3.48
2.30
0.677
0.787
0.737
0.328
0.368
0.350
0.100
0.121
0.111
0.133
0.191
0.161
0.112
0.134
0.127
Surfactant
Solution'
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
aFrom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.
b The values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At
viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not applicable.
°For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
eFor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
fFor surfactant solution, viscosity = 3 centipoise, surface tension =31.4 dynes/cm2
Example 14: Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
purchases and uses one thousand 55-gallon steel drums that contain a 10 percent solution of the chemical.
Further, it is assumed that the physical properties of the solution are similar to water. The solution is
pumped from the drums directly into a mixing vessel and the "empty" drums are triple-rinsed with water.
The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.
In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse
water. Therefore, the quantity transferred to the drum reclaimer should be reported as "zero." The annual
quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the mean
weight percent of residual solution remaining in water from pumping a steel drum (2.29 percent from the
preceding table, "Summary of Residue Quantities From Pilot-Scale Experimental Study") by the total
annual weight of solution in the drum (density of solution multiplied by drum volume). If the density is not
known, it may be appropriate to use the density of water (8.34 pounds per gallon):
(2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) x (1,000 drums) = 10,504 pounds solution
50
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
The concentration of the EPCRA Section 313 chemical in the solution is only 10%.
(10,504 pounds solution) x (10%) = 1,050 pounds
Therefore, 1,050 pounds of the chemical are transferred to the POTW.
Example 15: Reporting Metals and Metal
Category Compounds that are sent Off-site
A facility manufactures a product containing
elemental copper, exceeding the processing
threshold for copper. Various metal fabrication
operations for the process produce a wastewater
stream that contains some residual copper and
off-specification copper material. The
wastewater is collected and sent directly to a
POTW. Periodic monitoring data show that 500
pounds of copper were transferred to the POTW
in the reporting year. The POTW eventually
releases these chemicals to a stream. The off-
specification products (containing copper) are
collected and sent off-site to a RCRA Subtitle C
landfill. Sampling analyses of the product
combined with hazardous waste manifests were
used to determine that 1,200 pounds of copper
in the off-spec product were sent to the off-site
landfill.
Therefore, the facility must report 500 pounds in
Sections 6.1 and 8.Id, and 1200 pounds in
Sections 6.2 (waste code M65 (RCRA Subtitle
C Landfill) should be used) and 8.Id.
Note that for EPCRA Section 313 chemicals
that are not metals or metal category
compounds, the quantity sent for treatment at
POTWs and to other off-site treatment locations
must be reported in Section 8.7 - Quantity
Treated Off-site. However, if you know that
some or all of the chemical is not treated for
destruction at the off-site location you must
report that quantity in Section 8.1.
If you transfer the EPCRA Section 313 chemical in
wastes to an off-site facility for distinct and multiple
purposes, you must report those activities for each
off-site location, along with the quantity of the
reported EPCRA Section 313 chemical associated
with each activity. For example, your facility
transfers a total of 15,000 pounds of toluene to an
off-site location that will use 5,000 pounds for the
purposes of energy recovery, will enter 7,500
pounds into a recovery process, and will dispose of
the remaining 2,500 pounds. These quantities and
the associated activity codes must be reported
separately in Section 6.2. (See Figure 4 for a
hypothetical Section 6.2 completed for two off-site
locations, one of which receives the transfer of
15,000 pounds of toluene as detailed.) If you have
fewer than four total transfers in Section 6.2
Column A (see examples in Figure 4), an NA should
be placed in Column A of the first unused row to
indicate the termination of the sequence. If all four
rows are used, there is no need to terminate the
sequence. If there are more than four total transfers,
re-enter the name of the off-site location, address,
etc. in the next row (6.2.2) and then you should
enter NA when the sequence has terminated if there
are fewer than 8 (i.e. anytime there are fewer than 4
transfers listed in a Section 6.2 block, an NA should
be used to terminate the sequence).
Do not double or multiple count amounts transferred
off-site. For example, when a reported EPCRA
Section 313 chemical is sent to an off-site facility
for sequential activities, you should report the final
disposition of the toxic chemical.
6.2b Column B: Basis of Estimate
You must identify the basis for your estimates of the
quantities of the reported EPCRA Section 313
chemical in waste transferred to each off-site
location. Enter one of the following letter codes that
applies to the method by which the largest
percentage of the estimate was derived.
Ml Estimate is based on continuous monitoring
data or measurements for the EPCRA Section
313 chemical.
M2 Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA Section 313 chemical.
C Estimate is based on mass balance
calculations, such as calculation of the
Toxics Release Inventory Reporting Forms and Instructions
51
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amount of the EPCRA Section 313 chemical
in streams entering and leaving process
equipment.
El Estimate is based on published emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
E2 Estimate is based on site specific emission
factors, such as those relating release quantity
to through-put or equipment type (e.g., air
emission factors).
O Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment
was fully identified through monitoring data.
6.2c Column C: Type of Waste Management:
Disposal/ Treatment/Energy
Recovery/Recycling
You should enter one of the following M codes to
identify the type of disposal, treatment, energy
recovery, or recycling methods used by the off-site
location for the reported EPCRA Section 313
chemical. You must use more than one line and
code for a single location when distinct quantities of
the reported EPCRA Section 313 chemical are
subject to different waste management activities,
including disposal, treatment, energy recovery, or
recycling. You must use the code that represents the
ultimate disposition of the chemical.
If the EPCRA Section 313 chemical is sent off-site
for further direct reuse (e.g., an EPCRA Section 313
chemical in used solvent that will be used as
lubricant at another facility) and does not undergo a
waste management activity (i.e., release (including
disposal), treatment, energy recovery, or recycling
(recovery)) prior to that reuse, it need not be
reported in section 6.2 or section 8.
Incineration vs. Energy Recovery
You must distinguish between incineration which is
waste treatment, and legitimate energy recovery. For
you to claim that a reported EPCRA Section 313
chemical sent off-site is used for the purposes of
energy recovery and not for treatment for
destruction, the EPCRA Section 313 chemical must
have a significant heating value and must be
combusted in an energy recovery unit such as an
industrial boiler, furnace, or kiln. In a situation
where the reported EPCRA Section 313 chemical is
in a waste that is combusted in an energy recovery
unit, but the EPCRA Section 313 chemical does not
have a significant heating value, e.g., CFCs, you
should use code M54, Incineration/Insignificant
Fuel Value, to indicate that the EPCRA Section 313
chemical was incinerated in an energy recovery unit
but did not contribute to the heating value of the
waste.
Metals and Metal Category Compounds
Metals and metal category compounds will be
managed in waste either by being released
(including disposed) or by being recycled.
Remember that the release and other waste
management information that you report for metal
category compounds will be the total amount of the
parent metal released or recycled and NOT the
whole metal category compound. The metal has no
heat value and thus cannot be combusted for energy
recovery and cannot be treated because it cannot be
destroyed. Thus, transfers of metals and metal
category compounds for further waste management
should be reported as either a transfer for recycling
or a transfer for disposal. The applicable waste
management codes for transfers of metals and metal
category compounds for recycling are M24, metals
recovery, M93, waste broker - recycling, or M26,
other reuse/recovery. Applicable codes for transfers
for disposal include M10, M41, M62, M64, M65,
M66, M67, M73, M79, M81, M82, M90, M94, and
M99. These codes are for off-site transfers for
further waste management in which the waste
stream may be treated but the metal contained in the
waste stream is not treated and is ultimately
released. For example, M41 should be used for a
metal or metal category compound that is stabilized
in preparation for disposal.
Applicable codes for Part II, Section 6.2, column C
are:
Disposal
M10 Storage Only
M41 Solidification/Stabilization - Metals and
Metal Category Compounds only
M62 Wastewater Treatment (Excluding POTW) -
Metals and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M73 Land Treatment
M79 Other Land Disposal
52
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells Energy Recovery
M90 Other Off-Site Management M56 Energy Recovery
M94 Transfer to Waste Broker - Disposal M92 Transfer to Waste Broker - Energy
M99 Unknown Recovery
Treatment Recycling
M40 Solidification/Stabilization M20 Solvents/Organics Recovery
M50 Incineration/Thermal Treatment M24 Metals Recovery
M54 Incineration/Insignificant Fuel Value M26 Other Reuse or Recovery
M61 Wastewater Treatment (Excluding POTW) M28 Acid Regeneration
M69 Other Waste Treatment M93 Transfer to Waste Broker - Recycling
M95 Transfer to Waste Broker - Waste
Treatment
Toxics Release Inventory Reporting Forms and Instructions 53
-------
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.1
Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name
Street Address
City
State
Acme V
UULttbb 16241
/aste Services
51
Market Street
Anywhere
CO
Zip Code
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
3.
4.
5,000
7,500
2,500
NA
Co
unty
Hill
or\Af. i 's location under control of reporting r—i „ rjn NO
01/40 1 facility or parent company
(enter code)
l.O
2.C
3.0
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M56
2 M20
~ MOD
4. M
This off-site location receives a transfer of 15,000 pounds of toluene and will combust 5,000 pounds for the
purposes of energy recovery, will enter 7,500 pounds into a recovery process, and will dispose of the
remaining 2,500 pounds.
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.2
Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name „ ,
I VkTviKno
Street Address _
O« T7o~l1l+rr T>™
City
State
Dumfiy
f-,f^ Z'P Code
A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
12,500
NA
3.
4.
UUU10/72M.32
tion, Inc.
id
County
Buins
en^nn Is location under control of reporting •— | YHS FX1 No
80500 facility or parent company L- ' Yes ^
1. O
2.
3.
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
j M54
2. M
3. M
4. M
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is
part of a waste that is combusted for the purposes of energy recovery in an industrial furnace. Note that the
tetrachloroethylene should be reported using code M54 to indicate that it is combusted in an energy recovery
unit but it does not contribute to the heating value of the waste.
Figure 4. Hypothetical Section 6.2 Completed for Two Off-Site Locations
54
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Section 7. On-Site Waste Treatment,
Energy Recovery, and
Recycling Methods
You must report in this section the methods of waste
treatment, energy recovery, and recycling applied to
the reported EPCRA Section 313 chemical in wastes
on-site. There are three separate sections for
reporting such activities. (Section 7A column c and
Section 7A column e were previously deleted from
Form R and are not addressed below.)
Section 7A: On-Site Waste Treatment
Methods and Efficiency
Most of the chemical-specific information required
by EPCRA Section 313 that is reported on Form R
is specific to the EPCRA Section 313 chemical
rather than the waste stream containing the EPCRA
Section 313 chemical. However, EPCRA Section
313 does require that waste treatment methods
applied on-site to waste streams that contain the
EPCRA Section 313 chemical be reported. This
information is reportable regardless of whether the
facility actively applies treatment or the treatment of
the waste stream occurs passively. This information
is collected in Section 7A of Form R.
In Section 7A, you must provide the following
information if you treat waste streams containing
the reported EPCRA Section 313 chemical on-site:
(a) The general waste stream types containing the
EPCRA Section 313 chemical being reported;
(b) The waste treatment method(s) or sequence
used on all waste streams containing the
EPCRA Section 313 chemical; and
(c) The efficiency of each waste treatment
method or waste treatment sequence in
destroying or removing the EPCRA Section
313 chemical.
7A Column a: General Waste Stream
For each waste treatment method, indicate the type
of waste stream containing the EPCRA Section 313
chemical that is treated. Enter the letter code that
corresponds to the general waste stream type:
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and
slurries)
If a waste is a combination of water and organic
liquid and the organic content is less than 50
percent, report it as a wastewater (W). Slurries and
sludges containing water should be reported as solid
waste if they contain appreciable amounts of
dissolved solids, or solids that may settle, such that
the viscosity or density of the waste is considerably
different from that of process wastewater.
7A Column b: Waste Treatment Method(s)
Sequence
Enter the appropriate waste treatment code from the
list below for each on-site waste treatment method
used on a waste stream containing the EPCRA
Section 313 chemical, regardless of whether the
waste treatment method actually removes the
specific EPCRA Section 313 chemical being
reported. Waste treatment methods must be reported
for each type of waste stream being treated (i.e.,
gaseous waste streams, aqueous waste streams,
liquid non-aqueous waste streams, and solids).
Except for the air emission treatment codes, the
waste treatment codes are not restricted to any
medium.
Use a separate line in Section 7A for each general Waste streams containing the EPCRA Section 313
waste stream type. Report only information about
treatment of waste streams at your facility, not
information about off-site waste treatment.
If you do not perform on-site treatment of waste
streams containing the reported EPCRA Section 313
chemical, check the NA box at the top of Section
7A.
chemical may have a single source or may be
aggregates of many sources. For example, process
water from several pieces of equipment at your
facility may be combined prior to waste treatment.
Report waste treatment methods that apply to the
aggregate waste stream, as well as waste treatment
methods that apply to individual waste streams. If
your facility treats various wastewater streams
containing the EPCRA Section 313 chemical in
different ways, the different waste treatment
methods must be listed separately.
Toxics Release Inventory Reporting Forms and Instructions
55
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If your facility has several pieces of equipment
performing a similar service in a waste treatment
sequence, you may combine the reporting for such
equipment. It is not necessary to enter four codes to
cover four scrubber units, for example, if all four are
treating waste streams of similar character (e.g.,
sulfuric acid mist emissions), have similar influent
concentrations, and have similar removal
efficiencies. If, however, any of these parameters
differs from one unit to the next, each scrubber
should be listed separately.
If you are using the hardcopy paper form, and if
your facility performs more than eight sequential
waste treatment methods on a single general waste
stream, continue listing the methods in the next row
and renumber appropriately those waste treatment
method code boxes you used to continue the
sequence. For example, if the general waste stream
in box VA.la had nine treatment methods applied to
it, the ninth method would be indicated in the first
method box for row 7A.2a. The numeral "1" would
be crossed out, and a "9" would be inserted.
Treatment applied to any other general waste stream
types would then be listed in the next empty row. In
the scenario below, for instance, the second general
waste stream would be reported in row 7A.3a. See
Figure 5 for an example of a hypothetical section
7A.
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Instructions for Completing Part II of EPA Form R
Example 16: Calculating Releases and Other Waste Management Quantities
Your facility disposes of 14,000 pounds of lead chromate (PbCrCH.PbO) in an on-site landfill and transfers
16,000 pounds of lead selenite (PbSeO4) to an off-site land disposal facility. You would therefore be
submitting three separate reports on the following: lead compounds, selenium compounds, and chromium
compounds. However, the quantities you would be reporting would be the pounds of "parent" metal being
released on-site or transferred off-site for further waste management. All quantities are based on mass
balance calculations (See Section 5, Column B for information on Basis of Estimate and Section 6.2,
Column C for waste management codes and information on transfers of EPCRA Section 313 chemicals in
wastes). You would calculate releases of lead, chromium, and selenium by first determining the percentage
by weight of these metals in the materials you use as follows:
Lead Chromate (PbCrO4.PbO) Molecular weight = 546.37
Lead (2 Pb atoms) Atomic weight = 207.2 x 2 = 414.4
Chromium (1 Cr atom) Atomic weight = 51.996
Lead chromate is therefore (percent by weight)
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium
Lead Selenite (PbSeO4) Molecular weight = 350.17
Lead (1 Pb atom) Atomic weight = 207.2
Selenium (1 Se atom) Atomic weight = 78.96
Lead selenite is therefore (percent by weight)
(207.2/350.17) = 59.17% lead and
(78.96/350.17) = 22.55% selenium.
The total pounds of lead, chromium, and selenium disposed on or off-site from your facility are as follows:
Lead
Disposal on-site: 0.7585 x 14,000 = 10,619 pounds from lead chromate
Transfer off-site for disposal: 0.5917 x 16,000 = 9,467 pounds from lead selenite
Chromium
Disposal on-site: 0.0952 x 14,000 = 1,333 pounds from lead chromate
Selenium
Transfer off-site for disposal: 0.2255 x 16,000 = 3,608 pounds from lead selenite
Toxics Release Inventory Reporting Forms and Instructions 57
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Figure 5. Hypothetical Section 7A
Waste Treatment Codes
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
H040 Incineration—thermal destruction other than
use as a fuel
H071 Chemical reduction with or without
precipitation
H073 Cyanide destruction with or without
precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or without
pre-treatment
H081 Biological treatment with or without
precipitation
H082 Adsorption
HO 8 3 Air or steam stripping
H101 Sludge treatment and/or dewatering
HI03 Absorption
Hill Stabilization or chemical fixation prior to
disposal
HI 12 Macro-encapsulation prior to disposal
H121 Neutralization
HI22 Evaporation
HI23 Settling or clarification
HI24 Phase separation
HI29 Other treatment
7A Column d: Waste Treatment Efficiency
Estimate
In the space provided, enter the range code, based
upon the codes listed below, indicating the
percentage of the EPCRA Section 313 chemical
removed from the waste stream through destruction,
biological degradation, chemical conversion, or
physical removal. The waste treatment efficiency
(expressed as a range of percent removal) represents
the percentage of the EPCRA Section 313 chemical
destroyed or removed (based on amount or mass),
not merely changes in volume or concentration of
the EPCRA Section 313 chemical in the waste
stream. The efficiency, which can reflect the overall
removal from sequential treatment methods applied
to the general waste stream, refers only to the
percent destruction, degradation, conversion, or
removal of the EPCRA Section 313 chemical from
the waste stream; it does not refer to the percent
conversion or removal of other constituents in the
waste stream. The efficiency also does not refer to
the general efficiency of the treatment method for
any waste stream. For some waste treatment
methods, the percent removal will represent removal
by several mechanisms, as in an aeration basin,
where an EPCRA Section 313 chemical may
evaporate, biodegrade, or be physically removed
from the sludge.
58
Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Percent removal can be calculated as follows:
g-E)xioo%
i
where:
I = amount of the EPCRA Section 313 chemical in
the influent waste stream (entering the waste
treatment step or sequence) and
E = amount of the EPCRA Section 313 chemical in
the effluent waste stream (exiting the waste
treatment step or sequence).
Calculate the amount of the EPCRA Section 313
chemical in the influent waste stream by multiplying
the concentration (by weight) of the EPCRA Section
313 chemical in the waste stream by the total
amount or weight of the waste stream. In most
cases, the percent removal compares the treated
effluent to the influent for the particular type of
waste stream. For solidification of wastewater, the
waste treatment efficiency can be reported as code
El (greater than 99.9999 percent) if no volatile
EPCRA Section 313 chemicals were removed with
the water or evaporated into the air. Percent removal
does not apply to incineration because the waste
stream, such as wastewater or liquids, may not exist
in a comparable form after waste treatment and the
purpose of incineration as a waste treatment is to
destroy the EPCRA Section 313 chemical by
converting it to carbon dioxide and water or other
byproducts. In cases where the EPCRA Section 313
chemical is incinerated, the percent efficiency must
be based on the amount of the EPCRA Section 313
chemical destroyed or combusted, except for metals
or metal category compounds. In the cases in which
a metal or metal category compound is incinerated,
the efficiency is reported as code E6 (equal to or
greater than 0 percent, but less than or equal to 50
percent).
Similarly, an efficiency of zero must be reported for
any waste treatment method(s) that does not destroy,
chemically convert or physically remove the
EPCRA Section 313 chemical from the waste
stream.
For metal category compounds, the calculation of
the reportable concentration and waste treatment
efficiency must be based on the weight of the parent
metal, not on the weight of the metal compound.
Metals are not destroyed, only physically removed
or chemically converted from one form into another.
The waste treatment efficiency reported must
represent only physical removal of the parent metal
from the waste stream (except for incineration), not
the percent chemical conversion of the metal
compound. If a listed waste treatment method
converts but does not remove a metal (e.g.,
chromium reduction), the method must be reported
with a waste treatment efficiency of code E6 (equal
to or greater than 0 percent, but less than or equal to
50 percent.
EPCRA Section 313 chemicals that are strong
mineral acids neutralized to a pH of 6 or above are
considered treated at a 100 percent efficiency.
When calculating waste treatment efficiency,
EPCRA Section 313(g)(2) requires a facility to use
readily available data (including monitoring data)
collected pursuant to other provisions of law, or,
where such data are not readily available,
"reasonable estimates" of the amounts involved.
Waste Treatment Efficiency Range Codes:
E1 = greater than 99.9999%
E2 = greater than 99.99%, but less than or equal
to 99.9999%
E3 = greater than 99%, but less than or equal to
99.99%
E4 = greater than 95%, but less than or equal to
99%
E5 = greater than 50%, but less than or equal to
95%
E6 = equal to or greater than 0%, but less than or
equal to 50%
Section 7B On-site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy
recovery methods used on the reported EPCRA
Section 313 chemical.
EPA considers an EPCRA Section 313 chemical to
be combusted for energy recovery if the toxic
chemical has a significant heat value and is
combusted in an energy recovery device. If a
reported EPCRA Section 313 chemical is
incinerated on-site but does not contribute energy to
the process (e.g., chlorofluorocarbons), it must be
considered waste treated on-site and reported in
Section 7A. Metals and metal category compounds
cannot be combusted for energy recovery and
should NOT be reported in this section. Do not
include the combustion of fuel oils, such as fuel oil
#6, in this section. Energy recovery may take place
only in an industrial kiln, furnace, or boiler.
Toxics Release Inventory Reporting Forms and Instructions
59
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NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site energy recovery for a waste
stream that contains or contained the EPCRA
Section 313 chemical, check the NA box at the top
of Section 7B and enter NA in Section 8.2. If you
perform on-site energy recovery for the waste
stream that contains or contained the EPCRA
Section 313 chemical, enter the appropriate code in
Section 7B and enter the appropriate value in
Section 8.2. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter zero in 8.2. (Note:
for metals and metal compounds, you should only
report NA in Sections 7B and Section 8.2.)
Energy Recovery Codes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
If your facility uses more than one on-site energy
recovery method for the reported EPCRA Section
313 chemical, list the methods used in descending
order (greatest to least) based on the amount of the
EPCRA Section 313 chemical entering such
methods.
Section 7C On-site Recycling Processes
In Section 7C, you must report the recycling
methods used on the EPCRA Section 313 chemical.
In this section, use the codes below to report only
the recycling methods in place at your facility that
are applied to the EPCRA Section 313 chemical. Do
not list any off-site recycling activities. (Information
about off-site recycling must be reported in Part II,
Section 6, "Transfers of the Toxic Chemical in
Wastes to Off-site Locations.")
NA vs. a Numerical Value (e.g., Zero). If you do
not perform on-site recycling for the reported
EPCRA Section 313 chemical, check the NA box at
the top of Section 7C and enter NA in Section 8.4. If
you perform on-site recycling for the reported
EPCRA Section 313 chemical, enter the appropriate
code in Section 7C and enter the appropriate value
in Section 8.4. If this quantity is less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter 0 in Section 8.4.
On-Site Recycling Codes
H10 Metal recovery (by retorting, smelting, or
chemical or physical extraction
H20 Solvent recovery (including distillation,
evaporation, fractionation or extraction)
Other recovery or reclamation for reuse
H39
(including acid regeneration or other chemical
reaction process)
If your facility uses more than one on-site recycling
method for an EPCRA Section 313 chemical, enter
the codes in the space provided in descending order
(greatest to least) based on the volume of the
reported EPCRA Section 313 chemical recovered by
each process. If your facility uses more than ten
separate methods for recycling the reported EPCRA
Section 313 chemical on-site, then list the ten
activities that recover the greatest amount of the
EPCRA Section 313 chemical (again, in descending
order).
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Instructions for Completing Part II of EPA Form R
Example 17: On-Site Waste Treatment
A process at the facility generates a wastewater stream containing an EPCRA Section 313 chemical (chemical A). A
second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal (chemical B) and a
mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of completing
separate Form Rs for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being discharged to
a POTW. This system consists of an oil/water separator that removes 99 percent of chemical A; a neutralization tank in
which the pH is adjusted to 7.5, thereby destroying 100 percent of the mineral acid (chemical C); and a settling tank where
95 percent of the metal (chemical B) is removed from the water (and eventually landfilled off-site).
Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying this example shows how Section 7A should be completed for each chemical. First, on each FormR you
should identify the type of waste stream in Section 7A.la as wastewater (aqueous waste, code W). Next, on each Form R
you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless of whether the
operation affects the chemical for which you are completing the Form R (for instance, the first four blocks of Section 7A.lb
of all three Form Rs should show: H124 (phase separation), H121 (neutralization), H123 (settling or clarification), and N/A
(to signify the end of the treatment system). Note that Section 7A.lb is not chemical specific. It applies to the entire waste
stream being treated. Section 7A.ld applies to the efficiency of the entire system in destroying and/or removing the
chemical for which you are preparing the Form R. You should enter E4 when filing for chemical A, E5 for chemical B, and
El for chemical C.
Chemical A
7A.la
W
7A.lb
3.H123
6.
1.H124
4. N/A
7.
2.H121
5.
8.
TA.ld
E4
Chemical B
TA.la
W
7A.lb
3.H123
6.
1.H124
4. N/A
7.
2.H121
5.
8.
TA.ld
E5
Chemical C
TA.la
W
TA.lb
3.H123
6.
1.H124
4. N/A
1.
2.H121
5.
8.
TA.ld
El
Note that the quantity removed and/or destroyed is not reported in Section 1 and that the efficiency reported in Section
TA.ld refers to the amount of EPCRA Section 313 chemical destroyed and/or removed from the applicable waste stream.
The amount actually destroyed should be reported in Sections.6 (quantity treated on-site). For example, when completing
the Form R for Chemical B you should report "N/A" pounds in Section 8.6 because the metal has been removed from the
wastewater stream, but not actually destroyed. The quantity of Chemical B that is ultimately landfilled off-site should be
reported in Sections 6.2 and 8.1c. However, when completing the Form R for Chemical C you should report the entire
quantity in Section 8.6 because raising the pH to T.5 will completely destroy the mineral acid.
Toxics Release Inventory Reporting Forms and Instructions
61
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Example 18: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113.
Threshold quantities are exceeded for both of these EPCRA Section 313 chemicals, and you would,
therefore, submit two separate Form R reports. This waste stream is sent to an on-site industrial
furnace that uses the heat generated in a thermal hydrocarbon cracking process at your facility.
Because toluene has a significant heat value (17,440 BTU/pound) and the energy is recovered in an
industrial furnace, the code "U02" would be reported in Section 7B for the Form R submitted for
toluene.
However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of
Freon 113 in the industrial furnace is considered waste treatment, not energy recovery. You would
report Freon 113 as entering a waste treatment step (i.e., incineration), in Section 7A, column b. In
Section 7B the facility should report zero.
Section 8. Source Reduction and
Recycling Activities
This section includes the data elements mandated by
Section6607 of the Pollution Prevention Act of 1990
(PPA).
In Section 8, you must provide information about
source reduction activities and quantities of the
EPCRA Section 313 chemicals managed as waste.
For all appropriate questions, report only the
quantity, in pounds, of the reported EPCRA Section
313 chemical itself (except the dioxin and dioxin-
like compound category). Do not include the weight
of water, soil, or other waste constituents. When
reporting on the metal category compounds, you
should report only the amount of the metal portion
of the compound as you do when estimating release
and other waste management amounts.
Sections 8.1 through 8.9 must be completed for each
EPCRA Section 313 chemical. Section 8.10 must be
completed only if a source reduction activity was
newly implemented specifically (in whole or in part)
for the reported EPCRA Section 313 chemical
during the reporting year. Section 8.11 allows you to
indicate if you have attached additional optional
information on source reduction, recycling, or
pollution control activities implemented at any time
at your facility.
Sections 8.1 through 8.7 require reporting of
quantities for the current reporting year, the prior
year, and quantities anticipated in both the first year
immediately following the reporting year and the
second year following the reporting year (future
estimates).
Do not enter the values in Section 8 in gallons, tons,
liters, or any measure other than pounds. You must
also enter the values as whole numbers. Numbers
following a decimal point are not acceptable for
toxic chemicals other than those designated as PBT
chemicals. For PBT chemicals facilities should
report release and other waste management
quantities greater than 0.1 pound (except the dioxin
and dioxin-like compounds category) provided the
accuracy and the underlying data on which the
estimate is based supports this level of precision.
For the dioxin and dioxin-like compounds category
facilities should report at a level of precision
supported by the accuracy of the underlying data
and the estimation techniques on which the estimate
is based. However, the smallest quantity that need
be reported on the
Form R for the dioxin and dioxin-like compounds
category is 0.0001 grams (see Example 12).
Notwithstanding the numeric precision used when
determining reporting eligibility thresholds,
facilities should report on Form R to the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA's reporting software
and data management systems support data
precision to seven digits to the right of the decimal.
NA vs. a Numeric Value (e.g., Zero). You should
enter a numeric value in the relevant sections of
Section 8 if your facility has released, treated,
combusted for energy recovery or recycled any
quantity of an EPCRA Section 313 chemical during
the reporting year. If the aggregate quantity of that
toxic chemical was equal to or less than 0.5 pound
for a particular waste management method, you
should enter the value zero (unless the chemical is a
PBT chemical) in the relevant section.
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Instructions for Completing Part II of EPA Form R
However, if there has been no on-site or off-site
treatment, combustion for energy recovery or
recycling on the waste stream containing the
EPCRA Section 313 chemical, then you should
enter NA in the relevant section. (Note: for metals
and metal category compounds, you should enter
NA in Sections 8.2, 8.3, 8.6 and 8.7, as treatment
and combustion for energy recovery generally are
not applicable waste management methods for
metals and metal compounds). For Section 8.1b, NA
generally is not applicable recognizing the potential
for spills, leaks, or fugitive emissions of the EPCRA
Section 313 chemical. You should enter NA in
Section 8.8 if there were no remedial actions,
catastrophic events such as earthquakes, fires, or
floods or one time events not associated with normal
or routine production processes for that toxic
chemical. If there was a catastrophic event at your
facility, but you were able to prevent any releases
from occurring, then enter zero in Section 8.8.
Column A: Prior Year
Quantities for Sections 8.1 through 8.7 must be
reported for the year immediately preceding the
reporting year in column A. For reports due July 1,
2009 (reporting year 2008), the prior year is 2007.
Information available at the facility that may be
used to estimate the prior year's quantities include
the prior year's Form R submission, supporting
documentation, and recycling, energy recovery,
treatment, or disposal operating logs or invoices.
When reporting prior year estimates facilities are
not required to use quantities reported on the
previous year's form if better information is
available.
Column B: Current Reporting Year
Quantities for Sections 8.1 through 8.7 must be
reported for the current reporting year in column B.
Columns C and D: Following Year and Second
Following Year
Quantities for Sections 8.1 through 8.7 must be
estimated for 2009 and 2010. EPA expects
reasonable future quantity estimates using a logical
basis. Information available at the facility to
estimate quantities of the chemical expected during
these years include planned source reduction
activities, market projections, expected contracts,
anticipated new product lines, company growth
projections, and production capacity figures.
Respondents should take into account protections
available for trade secrets as provided in EPCRA
Section322 (42 USC 11042) for the chemical
identity.
Relationship to Other Laws
The reporting categories for quantities recycled,
used for energy recovery, treated, and disposed
apply to completing Section 8 of Form R as well as
to the rest of Form R. These categories are to be
used only for TRI reporting. They are not intended
for use in determining, under the Resource
Conservation and Recovery Act (RCRA) Subtitle C
regulations, whether a secondary material is a waste
when recycled. These definitions also do not apply
to the information that may be submitted in the
Biennial Report required under RCRA. In addition,
these definitions do not imply any future
redefinition of RCRA terms and do not affect EPA's
RCRA authority or authority under any other statute
administered by EPA.
Differences in terminology and reporting
requirements for EPCRA Section 313 chemicals
reported on Form R and for hazardous wastes
regulated under RCRA occur because EPCRA and
the PPA focus on specific chemicals, while the
RCRA regulations and the Biennial Report focus on
waste streams that may include more than one
chemical. For example, a RCRA hazardous waste
containing an EPCRA Section 313 chemical is
recycled to recover certain constituents of that
waste, but not the toxic chemical reported under
EPCRA Section 313. The EPCRA Section 313
chemical simply passes through the recycling
process and remains in the residual from the
recycling process, which is disposed. While the
waste may be considered recycled under RCRA, the
EPCRA Section 313 chemical constituent would be
considered to be disposed for TRI purposes.
Quantities Reportable in Sections 8.1 - 8.7
Section 8 of Form R uses data collected to complete
Part II, Sections 5 through 7. For this reason,
Section 8 should be completed last. Sections 8.1,
8.3, 8.5, 8.7, and 8.8 use data collected to complete
Sections 5 and 6 of Form R. The relationship
between Section s 5, 6, and 8.8 to Sections 8.1, 8.3,
8.5, and 8.7 are provided below in equation form.
Section 8.1. Beginning in the 2003 reporting year,
Section 8.1 was divided into four Subsections (8.la,
8.1b, 8.1c and 8.Id). Please refer to the following
equations that show the relationship between
Sections 5, 6 and 8.la through 8.Id. EPCRA
Toxics Release Inventory Reporting Forms and Instructions
63
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Section 329(8) defines release as "any spilling,
leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dumping,
or disposing [on-site or off-site] into the
environment (including the abandonment of barrels,
containers, and other closed receptacles)." In
Section 8.1, facilities report disposal and other
releases. This includes on-site disposal and other
releases in Section 5 and off-site disposal and other
releases in Section 6 (releases plus transfers to
disposal and transfers to POTWs of metals and
metal compounds), but excludes quantities reported
in Section 5 and 6 due to remedial actions,
catastrophic events, or non-production related
events (see the discussion on Section 8.8).
Example 19: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an
EPCRA Section 313 chemical in the
manufacture of a prescription drug. During the
reporting year (2005), the company received
approval from the Food and Drug
Administration to begin marketing their product
as an over-the-counter drug beginning in 2006.
This approval is publicly known and does not
constitute confidential business information. As
a result of this expanded market, the company
estimates that sales and subsequent production of
this drug will increase their use of the reported
EPCRA Section 313 chemical by 30 percent per
year for the two years following the reporting
year. The facility treats the EPCRA Section 313
chemical on-site and the quantity treated is
directly proportional to production activity. The
facility thus estimates the total quantity of the
reported EPCRA Section 313 chemical treated
for the following year (2005) by adding 30
percent to the amount in column B (the amount
for the current reporting year). The second
following year (2007) figure can be calculated
by adding an additional 30 percent to the amount
reported in column C (the amount for the
following year (2006) projection).
Metals and metal category compounds reported in
1) Section 6.2 as sent off-site for
stabilization/solidification (M41Cmetals) or
wastewater treatment (excluding POTWs)
(M62Cmetals) and/or 2) in Section 6.1 - discharges
to POTWs, should be reported in Section 8.1. These
quantities should NOT be reported in Section 8.7
because the metals are ultimately disposed.
Sections 8.1a and 8.1b. Toxic chemicals disposed
or otherwise released on-site are reported in 8. la or
8.1b as appropriate. Toxic chemicals sent off-site
for disposal are reported in 8. Ic or 8. Id.
Section 8.1a = Section 5.4.1 + Section 5.5.1A +
Section 5.5.1B B Section 8.8 (on-site release or
disposal due to catastrophic events)
Section 8.1b = Section 5.1 + Section 5.2 + Section
5.3 + Section 5.4.2 + Section 5.5.2 + Section
5.5.3A + Section 5.5.3B + Section 5.5.4 - Section
8.8 (on-site release or disposal due to
catastrophic events)
Sections 8.1c and 8.1d. Toxic chemicals transferred
off-site to POTWs or other off-site locations should
be reported in 8.1c or 8.Id as appropriate. For
example, quantities of a toxic chemical sent to a
POTW and subsequently sent to a landfill are
reported in Section 8.1c. Quantities of the toxic
chemical disposed or otherwise released by the
POTW to a stream are reported in Section 8.Id.
Metals and metal category compounds sent to
POTWs should be reported in one of these two
sections and should not be reported as treated for
destruction in Section 8.7.
Section 8.1c = Section 6.1 (portion of transfer
that is untreated and ultimately disposed of in
UIC Class I Wells, RCRA Subtitle C landfills,
and other landfills) + Section 6.2 (quantities
associated with M codes M64, M65 and M81) -
Section 8.8 (off-site disposal due to catastrophic
events)
Section 8.1d = Section6.1 (portion of transfer that
is untreated and ultimately disposed of in UIC
Class II-V wells, and disposal other than to
landfills) + Section 6.2 (quantities associated with
M codes M10, M41, M62, M66, M67, M73, M79,
M82, M90, M94, M99) - Section 8.8 (off-site
disposal due to catastrophic events)
Some chemicals in addition to metals and metal
category compounds might not be treated for
destruction at a POTW. If you are able to quantify
the amounts of a toxic chemical sent to a POTW
that are treated for destruction and disposed or
released from the POTW untreated, you should
divide the amount reported in Section 6.1 between
Sections 8.1c and 8.Id and 8.7 (quantity treated off-
site), as appropriate.
Sections 8.2 and 8.3. These relate to an EPCRA
Section 313 chemical or a mixture containing an
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Instructions for Completing Part II of EPA Form R
EPCRA Section 313 chemical that is used for
energy recovery on-site or is sent off-site for energy
recovery, unless it is a commercially available fuel
(e.g., fuel oil no. 6). For the purposes of reporting
on Form R, reportable on-site and off-site energy
recovery is the combustion of a waste stream
containing an EPCRA Section 313 chemical when:
(a) The combustion unit is integrated into an
energy recovery system (i.e., industrial
furnaces, industrial kilns, and boilers); and
(b) The EPCRA Section 313 chemical is
combustible and has a significant heating
value (e.g., 5000 BTU)
Note: Metals and metal category compounds cannot
be combusted for energy recovery. For metals and
metal category compounds, you should enter NA in
Sections 8.2 and 8.3.
Section 8.2 is reported in Section 8 only
Section 8.3 = Section6.2 (energy recovery)
SectionS.8 (off-site energy recovery due to
catastrophic events)
Sections 8.4 and 8.5. These relate to an EPCRA
Section 313 chemical in a waste that is recycled on-
site or is sent off-site for recycling.
Section 8.4 is reported in Section 8 only
Section 8.5 = Section 6.2 (recycling) - Section 8.8
(off-site recycling due to catastrophic events)
Section 8.6 and 8.7. These relate to an EPCRA
Section 313 chemical (except for most metals and
metal category compounds) or a waste containing an
EPCRA Section 313 chemical that is treated for
destruction on-site or is sent to a POTW or other
off-site location for treatment for destruction. Most
metal and category compounds are not reported in
this section because they cannot be destroyed (See
Appendix B).
Section 8.6 is reported in Section 8 only
Section 8.7 = Section 6.1 (excluding most
metal/metal category compounds) + Section 6.2
(treatment) - Section 8.8 (off-site treatment due
to catastrophic events)
Some chemicals in addition to metals and metal
category compounds might not be treated for
destruction at a POTW. If you are able to quantify
the amounts of a toxic chemical sent to a POTW
that are treated for destruction and disposed or
released from the POTW untreated, you should
divide the amount reported in Section 6.1 between
Sections 8.1c-d and 8.7 (quantity treated off-site), as
appropriate. Facilities should use their best readily
available information to determine the final
disposition of the toxic chemical sent to the POTW.
An EPCRA Section 313 chemical or an EPCRA
Section 313 chemical in a mixture that is a waste
under RCRA must be reported in Sections 8.1
through 8.7.
8.8 Quantity Released to the Environment as a
Result of Remedial Actions, Catastrophic Events,
or One Time Events Not Associated with
Production Processes
In Section 8.8, enter the total quantity of the
EPCRA Section 313 chemical disposed or released
directly into the environment or sent off-site for
recycling, energy recovery, treatment, or disposal
during the reporting year due to any of the following
events:
(1) remedial actions;
(2) catastrophic events such as earthquakes,
fires, or floods; or
(3) one time events not associated with
normal or routine production processes.
These quantities should not be included in Section
8.1.
The purpose of this section is to separate quantities
recycled, used for energy recovery, treated, or
released, including disposals that are associated with
normal or routine production operations from those
that are not. While all quantities disposed, released
recycled, combusted for energy recovery, or treated
may ultimately be preventable, this section separates
the quantities that are more likely to be reduced or
eliminated by process oriented source reduction
activities from those releases that are largely
unpredictable and are less amenable to such source
reduction activities. For example, spills that occur as
a routine part of production operations and could be
reduced or eliminated by improved handling,
loading, or unloading procedures are included in the
quantities reported in Section 8.1 through 8.7 as
Toxics Release Inventory Reporting Forms and Instructions
65
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appropriate. A total loss of containment resulting
from a tank rupture caused by a tornado would be
included in the quantity reported in Section 8.8.
Similarly, the amount of an EPCRA Section 313
chemical cleaned up from spills resulting from
normal operations during the reporting year would
not be included in Section 8.8. However, the
quantity of the reported EPCRA Section 313
chemical disposed from a remedial action (e.g.,
RCRA corrective action) to clean up the
environmental contamination resulting from past
practices should be reported in Section 8.8 because
they cannot currently be addressed by source
reduction methods. A remedial action for purposes
of Section 8.8 is a waste cleanup (including RCRA
and CERCLA operations) within the facility
boundary. Most remedial activities involve
collecting and treating contaminated material.
Also, releases caused by catastrophic events are to
be incorporated into the quantity reported in Section
8.8. Such releases may be caused by natural
disasters (e.g., hurricanes and earthquakes) or by
large scale accidents (e.g., fires and explosions). In
addition, releases due to one-time events not
associated with production (e.g., terrorist bombing)
are to be included in Section 8.8. These amounts are
generally unanticipated and cannot be addressed by
routine process oriented accident prevention
techniques. By checking your documentation for
calculating estimates made for Part II, Section 5,
"Quantity of the Toxic Chemical Entering Each
Environmental Medium On-site," you may be able
to identify disposal and release amounts from the
above sources. Emergency notifications under
CERCLA and EPCRA as well as accident histories
required under the Clean Air Act may provide
useful information. You should also check facility
incident reports and maintenance records to identify
one time or catastrophic events.
Note: While the information reported in Section 8.8
represents only remedial, catastrophic, or one time
events not associated with production processes,
Section 5 of Form R (on-site disposal and other
releases to the environment) and Section 6 (off-site
transfers for further waste management) must
include all on-site disposal and other releases and
transfers for disposal as appropriate, regardless of
whether they arise from catastrophic, remedial, or
routine process operations.
Avoid Double Counting in Sections 8.1 Through
8.8
Do not double or multiple count quantities in
Sections 8.1 through 8.8. The quantities reported in
each of those sections should be mutually exclusive.
Do not multiple count quantities entering sequential
reportable activities during the reporting year.
Quantities of the EPCRA Section 313 chemical
disposed or otherwise released into the environment
or otherwise managed as waste off-site due to
remedial actions; catastrophic events such as
earthquakes, fires, or floods; or unanticipated one
time events not associated with the production
process such as a drunk driver crashing his/her car
into a drum storage area. These quantities should be
reported in Section 8.8 only. For example, 10,000
pounds of diaminoanisole sulfate is released due to a
catastrophic event and is subsequently treated off-
site. The 10,000 pounds is reported in Section 8.8
but the amount subsequently treated off-site is not
reported in Section 8.7.
8.9 Production Ratio or Activity Index
For Section 8.9, you must provide a ratio of
reporting year production to prior year production,
or provide an "activity index" based on a variable
other than production that is the primary influence
on the quantity of the reported EPCRA Section 313
chemical recycled, used for energy recovery,
treated, disposed or released. The ratio or index
must be reported to the nearest tenths or hundredths
place (i.e., one or two digits to the right of the
decimal point). For EPCRA Section 313 PBT
chemicals, including the dioxin and dioxin-like
compounds category, you will report the same as for
chemicals that are not listed as PBT (i.e., up to one
or two digits to the right of the decimal point). If the
manufacture, processing, or use of the reported
EPCRA Section 313 chemical began during the
current reporting year, enter NA as the production
ratio or activity index. Note, this is not to be
reported as a percent (i.e., report 1.10 for a 10
percent increase, not 110 percent).
It is important to realize that if your facility reports
more than one reported EPCRA Section 313
chemical, the production ratio or activity index may
vary for different chemicals. For facilities that
manufacture reported EPCRA Section 313
chemicals, the quantities of the EPCRA Section 313
chemical(s) produced in the current and prior years
provide a good basis for the ratio because that is the
primary business activity associated with the
reported EPCRA Section 313 chemical(s). In most
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Instructions for Completing Part II of EPA Form R
cases, the production ratio or activity index must be
based on some variable of production or activity
rather than on EPCRA Section 313 chemical or
material usage. Indices based on EPCRA Section
313 chemical or material usage may reflect the
effect of source reduction activities rather than
changes in business activity. EPCRA Section 313
chemical or material usage is therefore not a basis to
be used for the production ratio or activity index
where the EPCRA Section 313 chemical is
"otherwise used" (i.e., non incorporative activities
such as extraction solvents, metal degreasers, etc.).
While several methods are available to the facility
for determining this data element, the production
ratio or activity index must be based on the variable
that most directly affects the quantities of the
EPCRA Section 313 chemical recycled, used for
energy recovery, treated, disposed or released.
Examples of methods available include:
(1) Amount of EPCRA Section 313 chemical
manufactured in 2009 divided by the amount
of EPCRA Section 313 chemical
manufactured in 2008; or
(2) Amount of product produced in 2009 divided
by the amount of product produced in 2008.
Example 20: Quantity Released to the
Environment as a Result of Remedial
Actions, Castastrophic Events, or One-Time
Events Not Associated with Production
Processes.
A chemical manufacturer produces an EPCRA
Section 313 chemical in a reactor that operates
at low pressure. The reactants and the EPCRA
Section 313 chemical product are piped in and
out of the reactor at monitored and controlled
temperatures. During normal operations, small
amounts of fugitive emissions occur from the
valves and flanges in the pipelines.
Due to a malfunction in the control panel
(which is state-of-the-art and undergoes routine
inspection and maintenance), the temperature
and pressure in the reactor increase, the reactor
ruptures, and the EPCRA Section 313 chemical
is released. Because the malfunction could not
be anticipated and, therefore, could not be
reasonably addressed by specific source
reduction activities, the amount released is
included in Section 8.8. In this case, much of
the EPCRA Section 313 chemical is released as
a liquid and pools on the ground. It is estimated
that 1,000 pounds of the EPCRA Section 313
chemical pooled on the ground and was
subsequently collected and sent off-site for
treatment. In addition, it is estimated that
another 200 pounds of the EPCRA Section 313
chemical vaporized directly to the air from the
rupture. The total amount reported in Section
8.8 is the 1,000 pounds that pooled on the
ground (and subsequently sent off-site), plus
the 200 pounds that vaporized into the air, a
total of 1,200 pounds. The quantity sent off-site
must also be reported in Section 6 (but not in
Section 8.7) and the quantity that vaporized
must be reported as a fugitive emission in
Section 5 (but not in Section 8.1b).
Toxics Release Inventory Reporting Forms and Instructions
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8.10 Did Your Facility Engage in Any Source
Reduction Activities for This Chemical
During the Reporting Year?
Section 8.10 must be completed only if a source
reduction activity was newly implemented
specifically (in whole or in part) for the reported
EPCRA Section 313 chemical during the reporting
year. If your facility engaged in any source
reduction activity for the reported EPCRA Section
313 chemical during the reporting year, report the
activity that was implemented and the method used
to identify the opportunity for the activity
implemented. If your facility did not engage in any
source reduction activity for the reported EPCRA
Section 313 chemical, enter NA in Section 8.10.1.
Source reduction means any practice that:
• Reduces the amount of any hazardous
substance, pollutant, or contaminant entering
any waste stream or otherwise released into the
environment (including fugitive emissions)
prior to recycling, energy recovery, treatment,
or disposal; and
• Reduces the hazards to public health and the
environment associated with the release of such
substances, pollutants, or contaminants.
The term includes equipment or technology
modifications, process or procedure modifications,
reformulation or redesign of products, substitution
of raw materials, and improvements in
housekeeping, maintenance, training, or inventory
control.
The term "source reduction" does not include any
practice that alters the physical, chemical, or
biological characteristics or the volume of a
hazardous substance, pollutant, or contaminant
through a process or activity that itself is not
integral to and necessary for the production of a
product or the providing of a service.
Source reduction activities do not include recycling,
using for energy recovery, treating, or disposing of
an EPCRA Section 313 chemical. Report in this
section only the source reduction activities
implemented to reduce or eliminate the quantities
reported in Sections 8.1 through 8.7. The focus of
the section is only those activities that are applied to
reduce routine or reasonably anticipated releases
and quantities of the reported EPCRA Section 313
chemical recycled, treated, used for energy
recovery, or disposed. Do not report in this section
any activities taken to reduce or eliminate the
quantities reported in Section 8.8. If you have fewer
than four source reduction codes in Section 8.10, an
NA should be placed in the first column of the first
unused row to indicate the termination of the
sequence. If all four rows are used, there is no need
to terminate the sequence. If there are more than
four source reduction codes, photocopy Page 5 of
Form R as many times as necessary and then
number the boxes consecutively for each source
reduction activity. Enter NA when the sequence has
terminated, unless the sequence ends at 4, 8, 12, 16,
etc. source reduction codes.
Example 21: Avoiding Double-Counting Quantities in Sections 8.1 through 8.7
5,000 pounds of an EPCRA Section 313 chemical enters a treatment operation. Three thousand pounds of
the EPCRA Section 313 chemical exits the treatment operation and then enters a recycling operation. Five
hundred pounds of the EPCRA Section 313 chemical are in residues from the recycling operation that is
subsequently sent off-site to a landfill for disposal. These quantities would be reported as follows in
Section 8:
Section 8.1c: 500 pounds disposed
Section 8.4: 2,500 pounds recycled
Section 8.6: 2000 pounds treated (5,000 that initially entered - 3,000 that subsequently entered recycling)
To report that 5,000 pounds were treated, 3,000 pounds were recycled, and that 500 pounds were sent off-
site for disposal would result in over-counting the quantities of EPCRA Section 313 chemical recycled,
treated, and disposed by 3,500 pounds.
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Example 22: Determining a Production Ratio
Your facility's only use of toluene is as a paint carrier for a painting operation. You painted 12,000
refrigerators in the current reporting year and 10,000 refrigerators during the preceding year. The
production ratio for toluene in this case is 1.2 (12,000/10,000) because the number of refrigerators
produced is the primary factor determining the quantity of toluene to be reported in Sections 8.1 through
8.7.
A facility manufactures inorganic pigments, including titanium dioxide. Hydrochloric acid (acid aerosols)
is produced as a waste byproduct during the production process. An appropriate production ratio for
hydrochloric acid (acid aerosols) is the annual titanium dioxide production, not the amount of byproduct
generated. If the facility produced 20,000 pounds of titanium dioxide during the reporting year and 26,000
pounds in the preceding year, the production ratio would be 0.77 (20,000/26,000).
Toxics Release Inventory Reporting Forms and Instructions 69
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Example 23: Determining an Activity Index
Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and
between color changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers to
reduce color carryover. During the preceding year, the facility produced 2,000 pounds of yellow dye in
January, 9,000 pounds of green dye for February through September, 2,000 pounds of red dye in
November, and another 2,000 pounds of yellow dye in December. This adds up to a total of 15,000 pounds
and four color changeovers. During the reporting year, the facility produced 10,000 pounds of green dye
during the first half of the year and 10,000 pounds of red dye in the second half. If your facility uses glycol
ethers in this cleaning process only, an activity index of 0.5 (based on two color changeovers for the
reporting year divided by four changeovers for the preceding year) is more appropriate than a production
ratio of 1.33 (based on 20,000 pounds of dye produced in the current year divided by 15,000 pounds in the
preceding year). In this case, an activity index, rather than a production ratio, better reflects the factors that
influence the amount of solvent recycled, used for energy recovery, treated, or disposed or released.
A facility that manufactures thermoplastic composite parts for aircraft uses toluene as a wipe solvent to
clean molds. The solvent is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds
are cleaned on an as-needed basis that is not necessarily a function of the parts production rate. Operators
cleaned 5,200 molds during the reporting year, but only cleaned 2,000 molds in the previous year. An
activity index of 2.6 (5,200/2,000) represents the activities involving toluene usage in the facility. If the
molds were cleaned after 1,000 parts were manufactured, a production ratio would equal the activity index
and either could be used as the basis for the index.
A facility manufactures surgical instruments and cleans the metal parts with 1,1,1-trichloromethane in a
vapor degreaser. The degreasing unit is operated in a batch mode and the metal parts are cleaned according
to an irregular schedule. The activity index can be based upon the total time the metal parts are in the
degreasing operation. If the degreasing unit operated 3,900 hours during the reporting year and 3,000 hours
the prior year, the activity index is 1.3 (3,900/3,000).
Example 24: "NA" is Entered as the Production Ratio or Activity Index
Your facility began production of semiconductor chips during this reporting year. Perchloroethylene is used
as a cleaning solvent for this operation and this is the only use of the EPCRA Section 313 chemical in your
facility. You would enter NA in Section 8.9 because you have no basis of comparison in the prior year for
the purposes of developing the activity index.
70 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 25: Determining the Production Ratio Based on a Weighted Average
At many facilities, a reported EPCRA Section 313 chemical is used in more than one production process. In
these cases, a production ratio or activity index can be estimated by weighting the production ratio for each
process based on the respective contribution of each process to the quantity of the reported EPCRA Section
313 chemical recycled, used for energy recovery, treated, or disposed.
Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in the
reporting year and 14,500 were produced in the prior year. There were no significant design modifications
that changed the total surface area to be painted for each bike. The bicycle production ratio is 1.1
(16,000/14,500). You estimate 12,500 pounds of toluene recycled, used for energy recovery, treated,
disposed or released as a result of bicycle production. Your facility also uses toluene as a solvent in a glue
that is used to make components and add-on equipment for the bicycles. Thirteen thousand components
were manufactured in the reporting year as compared to 15,000 during the prior year. The production ratio
for the components using toluene is 0.87 (13,000/15,000). You estimate 1,000 pounds of toluene treated,
recycled, used for energy recovery, disposed or released as a result of components production. A production
ratio can be calculated by weighting each of the production ratios based on the relative contribution each
has to the quantities of toluene treated, recycled, used for energy recovery, disposed or released during the
reporting year (13,500 pounds). The production ratio is calculated as follows:
Production ratio = 1.1 x (12,500/13,500) + 0.87 x (1,000/13,500) = 1.08
Toxics Release Inventory Reporting Forms and Instructions 71
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Example 26: Source Reduction
A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints contain
EPCRA Section 313 chemicals. By examining the gluing process, the facility discovered that a new drum of
glue is opened at the beginning of each shift, whether the old drum is empty or not. By adding a mechanism
that prevents the drum from being changed before it is empty, the need for disposal of the glue is eliminated
at the source. As a result, this activity is considered source reduction. The painting process at this facility
generates a solvent waste that contains an EPCRA Section 313 chemical that is collected and recovered.
The recovered solvent is used to clean the painting equipment. The recycling activity does not reduce the
amount of EPCRA Section 313 chemical recycled, and therefore is not considered a source reduction
activity.
Source Reduction Activities
You must enter in the first column of Section 8.10,
"Source Reduction Activities," the appropriate
code(s) indicating the type of actions taken to
reduce the amount of the reported EPCRA Section
313 chemical disposed or otherwise released (as
reported in Section 8.1), used for energy recovery
(as reported in Sections 8.2-8.3), recycled (as
reported in Sections 8.4-8.5), or treated (as
reported in Sections 8.6-8.7). The list of codes
below includes many, but not all, of the codes
provided in the RCRA biennial report. Remember
that source reduction activities include only those
actions or techniques that reduce or eliminate the
amounts of the EPCRA Section 313 chemical
reported in Sections 8.1 through 8.7. Actions taken
to recycle, combust for energy recovery, treat, or
dispose of the EPCRA Section 313 chemical are
not considered source reduction activities.
Source Reduction Activity Codes:
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes made in operating practices
Inventory Control
W21 Instituted procedures to ensure that
materials do not stay in inventory beyond
shelf-life
W22 Began to test outdated material — continue
to use if still effective
W23 Eliminated shelf-life requirements for
stable materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange
materials that would otherwise be
discarded
W29 Other changes made in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading,
unloading, and transfer operations
W33 Installed overflow alarms or automatic
shut-off valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other changes made in spill and leak
prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted re-circulation within a process
W52 Modified equipment, layout, or piping
W53 Used a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to
bulk containers to minimize discarding of
empty containers
W5 8 Other process modifications made
Cleaning and Decreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning
devices (from solvents or other materials)
W61 Changed to aqueous cleaners (from
solvents or other materials)
W63 Modified containment procedures for
cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
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W71 Other cleaning and decreasing
modifications made
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications made
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of product
W83 Modified packaging
W89 Other product modifications made
Methods to Identify Activity
In columns a through c of Section 8.10, the
"Methods to Identify Activity," you must enter one
or more of the following code(s) that correspond to
those internal and external method(s) or
information sources you used to identify the
possibility for a source reduction activity
implementation at your facility. If more than three
methods were used to identify the source reduction
activity, enter only the three codes that contributed
most to the decision to implement the activity.
T01 Internal pollution prevention opportunity
audit(s)
T02 External pollution prevention opportunity
audit(s)
T03 Materials balance audits
T04 Participative team management
T05 Employee recommendation (independent
of a formal company program
T06 Employee recommendation (under a
formal company program
T07 State government technical assistance
program
T08 Federal government technical assistance
program
T09 Trade association/industry technical
assistance program
T10 Vendor assistance
Til Other
8.11 Is Additional Optional Information on
Source Reduction, Recycling, or
Pollution Control Activities Included
with this Report?
Check "Yes" for this data element if you wish to
submit any additional optional information on
source reduction, recycling, or pollution control
activities you have implemented in the reporting
year or in prior years for the reported EPCRA
Section 313 chemical. If you are using TRI-MEweb
to submit your report, you can use the pull-down
text box feature to describe your source reduction,
recycling, or pollution control activities. You may
submit such additional information in hard-copy in
addition to, or instead of, the information supplied
in the TRI-MEweb text box feature. If you wish to
submit by regular mail, please use the following
address:
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8
To submit hard-copy information for Section 8.11
by certified or overnight mail, use the following
address:
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
All information submitted in hard-copy must
include the name, address, and TRIFID number for
the facility submitting the information.
If there is a contact person at the facility, other than
the technical or public contact provided in Part I,
Section 4, the summary page should include that
person's name and telephone number for
individuals who wish to obtain further information
about those activities. Also submit a copy of this
additional information to the appropriate state
agency as part of the Form R submittal to that
agency.
Toxics Release Inventory Reporting Forms and Instructions
73
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D. Instructions for Completing
Form R Schedule 1 (Dioxin and
Dioxin-like Compounds)
D. 1 What is the Form R Schedule 1 ?
The Form R Schedule 1 is a four-page form that
mirrors the data elements from Form R Part II
Chemical-Specific Information sections 5, 6, and
8 (current year only). The Form R Schedule 1
requires the reporting of the individual grams
data for each member of the dioxin and dioxin -
like compounds category present, and is
submitted as an adjunct to the Form R.
Beginning with reporting year 2008, facilities
that file Form R reports for the dioxin and
dioxin-like compounds category are required to
determine if they have any of the information
required by the new Form R Schedule 1.
Facilities that have any of the information
required by Form R Schedule 1 must submit a
Form R Schedule 1 in addition to the Form R.
D.2 Who is required to file a Form R
Schedule 1?
Only facilities that file reports for the dioxin and
dioxin-like compounds category may be required
to file a Form R Schedule 1. Facilities that have
any of the data required by Form R Schedule 1
for the individual members of the dioxin and
dioxin-like compounds category must submit a
Form R Schedule 1, in addition to the Form R.
EPA notes that dioxin and dioxin-like
compounds are not measured as a total quantity;
the measurements are based on the individual
compounds within the category. Emission factors
for dioxin and dioxin-like compounds are also
based on emission factors for the individual
compounds within the category. EPA's guidance
document for dioxin and dioxin-like compounds
(Emergency Planning And Community Right-
To-Know Act - Section 313: Guidance for
Reporting Toxic Chemicals within the Dioxin and
Dioxin-like Compounds Category, EPA-745-B-
00-021, December 2000) includes tables that
contain the emission factors for the individual
members of the dioxin and dioxin-like compounds
category. Since measured data and emission
factor data are based upon data for the individual
members of the dioxin and dioxin-like compounds
category, the information required by Form R
Schedule 1 should be available to facilities that
file Form R reports for the dioxin and dioxin-like
compounds category.
D.3 What information is reported on
the Form R Schedule 1 ?
The only data reported on the Form R Schedule 1
is the mass quantity information required in
sections 5, 6, and 8 (current year only) of the
Form R. All of the other information required in
sections 5, 6, and 8 of the Form R (off-site
location names, stream or water body names, etc.)
would be the same so this information is not
duplicated on Form R Schedule 1. For example,
if a facility reported 5.3306 grams on Form R
Section 5.1 for fugitive or non-point air emissions
for the dioxin and dioxin-like compounds
category then the facility would report on the
Form R Schedule 1 the grams data for each
individual member of the category that
contributed to the 5.3306 gram total. The sum of
the gram quantities reported for each individual
member of the category should equal the total
gram quantity reported for the category on Form
R for each data element (see examples below).
The NA box has the same meaning on Form R
Schedule 1 as it does on the Form R and should
only be marked if it is marked on the Form R.
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Form R Section 5 Example
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
5.1
Fugitive or non-point
air emissions
N
A
A. Total Release (pounds/year*)
(Enter a range code** or
estimate)
5.3306
B. Basis of
Estimate
(enter code)
M
C. % From
Stormwater
Form R Schedule 1 Section 5 Example
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM
ONSITE
t~
1
o
•3
_g
T3
1
1
5
fl
£
Efl
3
2
p
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions
0.0035
0.0059
0.0071
0.0008
0.0065
0.0923
0.5720
0.0723
0.0695
0.0399
0.3562
0.1309
0.0132
0.0815
1.4625
0.3126
2.1039
N
A
Stack or point
air emissions
Discharges to receiving streams or water bodies
(enter data for one stream or water body per box)
5.3.1
5.3.2
5.3.3
The Form R Schedule 1 provides boxes for recording the gram quantities for all 17 individual members of
the dioxin and dioxin-like compounds category. The boxes on the Form R Schedule 1 for each release type
are divided into 17 boxes. Each of the boxes (1-17) correspond to the individual members of the dioxin
category as presented in Table I.
Table I
Box # CAS# Chemical Name
1 01746-01-6 2,3,7,8-Tetrachlorodibenzo-p-dioxin
2 40321-76-4 1,2,3,7,8-Pentachlorodibenzo- p-dioxin
3 39227-28-6 1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin
4 57653-85-7 1,2,3,6,7,8-Hexachlorodibenzo- p-dioxin
5 19408-74-3 1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
6 35822-46-9 1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
7 03268-87-9 1,2,3,4,6,7,8,9-Octachlorodibenzo- p-dioxin
8 51207-31-9 2,3,7,8-Tetrachlorodibenzofuran
9 57117-41-6 1,2,3,7,8-Pentachlorodibenzofuran
Abbreviation
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
Toxics Release Inventory Reporting Forms and Instructions
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10 57117-31-4 2,3,4,7,8-Pentachlorodibenzofuran 2,3,4,7,8-PeCDF
11 70648-26-9 1,2,3,4,7,8-Hexachlorodibenzofuran 1,2,3,4,7,8-HxCDF
12 57117-44-9 1,2,3,6,7,8-Hexachlorodibenzofuran 1,2,3,6,7,8-HxCDF
13 72918-21-9 1,2,3,7,8,9-Hexachlorodibenzofuran 1,2,3,7,8,9-HxCDF
14 60851-34-5 2,3,4,6,7,8-Hexachlorodibenzofuran 2,3,4,6,7,8-HxCDF
15 67562-39-4 1,2,3,4,6,7,8-Heptachlorodibenzofuran 1,2,3,4,6,7,8-HpCDF
16 55673-89-7 1,2,3,4,7,8,9-Heptachlorodibenzofuran 1,2,3,4,7,8,9-HpCDF
17 39001-02-0 1,2,3,4,6,7,8,9-Octachlorodibenzofuran 1,2,3,4,6,7,8,9-OCDF
It is extremely important that facilities enter their grams data for the individual members of the category
based on the box numbers in Table I (do not use the listing order from the 2007 or earlier versions of the
reporting instructions). This information will be used to calculate toxic equivalency values using toxic
equivalency factors that are specific to each member of the category. As with reporting on the Form R,
facilities should report on the Form R Schedule 1 to the level of accuracy that their data supports, up to
seven digits to the right of the decimal. EPA's reporting software and data management systems support
data precision to seven digits to the right of the decimal. EPA strongly encourages facilities that report for
the dioxin and dioxin-like compounds category to file their reports electronically to reduce the potential for
errors when transferring the individual grams data from hard copy reports.
76 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on EPA Form A Certification Statement
E. Facility Eligibility
Determination for Alternate
Threshold and for
Reporting on EPA Form A
This section will help to determine whether you
can submit the simplified Form A Certification
Statement (hereafter referred to as Form A). The
criteria are based on the total annual reportable
amount of the listed chemical or chemical category
and the amount manufactured, processed, or
otherwise used. Note that, effective in Reporting
Year 2008, the TRI Burden Reduction Rule has
been voided by Congress. The criterion for using
Form A has returned to what they were prior to
Reporting Year 2006. The criteria are explained
below. For more information about the final rule,
see the TRI homepage at http://www.epa.gov/tri/.
E.I Alternate Threshold
On November 30, 1994, EPA published a final rule
(59 FR 61488) that provides qualifying facilities an
alternate threshold of 1 million pounds. Eligible
facilities wishing to take advantage of this option
may certify on a simplified two-page form referred
to as Form A Certification Statement and do not
have to use Form R. The "TRI Alternate Threshold
for Facilities with Low Annual Reportable
Amounts," provides facilities otherwise meeting
EPCRA section 313 reporting thresholds the option
of certifying on Form A provided that they do not
exceed 500 pounds for the total annual reportable
amount (defined below) for that chemical, and that
their amounts manufactured or processed or
otherwise used do not exceed one-million pounds.
As with determining section 313 reporting
thresholds, amounts manufactured, processed, or
otherwise used are to be considered independently.
This modification does not apply to forms being
submitted on or before July 1, 1995 (covering the
1994 reporting year). If you fill out a Form A for
an EPCRA section 313 chemical, do not fill out a
Form R for that same chemical.
However, there is an exception to the alternate
threshold rule described in the preceding
paragraph. All PBT chemicals (except certain
instances of reporting lead in stainless steel, brass
or bronze alloys) are excluded from eligibility for
the alternate threshold.
E.2 What is the Form A Certification
Statement?
The Form A, which is described as the
"certification statement" in 59 FR 61488, is
intended as a means to reduce the compliance
burden associated with EPCRA section 313. If a
facility chooses to use Form A as a substitute for
Form R for any eligible chemical, it must be
submitted on an annual basis. Facilities wishing to
take advantage of this burden reducing option may
only submit Form A for chemicals that meet the
conditions described in section E.I, Alternate
Threshold, and should not submit a Form R to the
TRI Data Processing Center for the same
chemicals. The information submitted on the Form
A includes facility identification information and
the chemical or chemical category identity. The
information submitted on the Form A will appear
in the TRI data base in the same manner that
information submitted on Form R appears. An
approved Form A has been included in this
Reporting Forms and Instructions document.
E.3 What Is the Annual Reportable
Amount (ARA)?
For the purpose of this optional reporting
modification, the annual reportable amount (ARA)
is equal to the combined total quantities released at
the facility (including disposed within the facility),
treated at the facility (as represented by amounts
destroyed or converted by treatment processes),
recovered at the facility as a result of recycling
operations, combusted for the purpose of energy
recovery at the facility, and amounts transferred
from the facility to off-site locations for the
purpose of recycling, energy recovery, treatment,
and/or disposal. These quantities correspond to the
sum of amounts reportable for data elements on
EPA Form R (EPA Form 9350-1; Rev. 10/09) as
Part II column B of section 8, data elements 8.1
(quantity released), 8.2 (quantity used for energy
recovery on-site), 8.3 (quantity used for energy
recovery off-site), 8.4 (quantity recycled onsite),
8.5 (quantity recycled off-site), 8.6 (quantity
treated on-site), and 8.7 (quantity treated off-site).
Toxics Release Inventory Reporting Forms and Instructions
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E.4 Recordkeeping
Each owner or operator who determines that they
are eligible, and wishes to apply the alternate
threshold to a particular chemical, must retain
records substantiating this determination for a
period of three years from the date of the
submission of the Form A. These records must
include sufficient documentation to support
calculations as well as the calculations made by the
facility that confirm their eligibility for each
chemical for which the alternate threshold was
applied.
A facility that fits within the category description,
and manufactures, processes or otherwise uses no
more than one million pounds of an EPCRA
Section 313 chemical annually, and whose
owner/operator elects to take advantage of the
alternate threshold, is not considered an EPCRA
Section 313 covered facility for that chemical for
the purpose of submitting a Form R. This
determination may provide further regulatory relief
from other federal or state regulations that apply to
facilities on the basis of their EPCRA Section 313
reporting status. A facility will need to reference
other applicable regulations to determine if their
actual requirements may be affected by this
reporting modification.
E.5 Multi-establishment Facilities
For the purposes of using Form A, the facility must
also make its determination based upon the entire
facility's operations including all of its
establishments (see 59 FR 61488 for greater
detail). If the facility as a whole is able to take
advantage of the alternate threshold, a single Form
A is required. The eligibility to submit a Form A
must be made on a whole facility determination.
Thus, all of the information necessary to make the
determination must be assembled to the facility
level.
E. 6 Trade Secrets
When making a trade secret claim on a Form A
submission, EPA is requiring that a facility submit
a unique Form A for each EPCRA Section 313
chemical meeting the conditions of the alternate
threshold. Facilities may assert a trade secrecy
claim for a chemical identity on the Form A as on
the Form R. Reports submitted on a per chemical
basis protect against the disclosure of trade secrets.
Form As with trade secrecy claims, like Form Rs
with similar claims, will be separately handled
upon receipt to protect against disclosure.
Commingling trade secret chemical identities with
non trade secret chemical identities on the same
submission increases the risk of disclosure.
Do not submit trade secret reports
electronically.
E. 7 Metals and Metal Category
Compounds
For metal category compounds, the amount applied
toward the ARA is the amount of parent metal
waste that is reported on Form R, but the
thresholds apply to the amount of metal category
compounds manufactured, processed, or otherwise
used. For Form A certification involving both
listed parent metals and associated metal
compounds, the one million pound alternate
threshold must be applied separately to the listed
parent metal and the associated metal
compound(s). Threshold determinations must be
made independently for each because they are
separately listed EPCRA Section 313 chemicals.
• If the threshold is exceeded for the listed parent
metal but not the associated metal category
compounds, then the releases of metal reported
on Form R for the parent metal need not
include the releases from the metal category
compounds.
• If both the parent metal and the associated
metal compounds exceed the alternate
threshold, then the facility has the option of
filing one Form R for both, using the metal
category compound name and reporting total
releases based on parent metal content.
• If neither the parent metal nor the associated
metal compounds exceed the alternate
threshold, then the facility must use a separate
listing on Form A for each, since the reporting
thresholds must be applied to each listed parent
metal and all compounds in the associated
compound category. EPA believes it is
appropriate to make the distinction between
filing the Form R and Form A because the
Form R accounts for amounts of metal released
or otherwise managed and Form A verifies that
the alternate threshold for each listed chemical
or chemical category has not been exceeded.
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on EPA Form A Certification Statement
Similarly, separate listings on Form A must be
submitted for all other listed chemicals even if
EPA allows one listing on Form R to be filed for
two or more listed chemicals (e.g., o-xylene, p-
xylene and xylene (mixed isomers)). For example,
if a facility processes in three separate process
streams, xylene (mixed isomers), o-xylene, and p-
xylene, and exceeds the conditions of the alternate
threshold for each of these listed substances, the
facility may combine the appropriate information
on the o-xylene, p-xylene, and xylene (mixed
isomers) into one Form R, but cannot combine the
reports into one listing on Form A.
Facilities that process o-xylene, p-xylene, and
xylene (mixed isomers) in separate process streams
and do not exceed the conditions of the alternate
threshold for one or more of the compounds may
submit a separate Form A for each of the forms of
xylene meeting the alternate threshold and report
on Form R for those forms that do not. Similar to
reporting on the parent metals and their associated
category compounds described above, facilities
that separately process all types (i.e., isomers) of
xylene with individual activity levels within the
conditions of the alternate threshold should file a
separate Form A for each type of xylene.
Beginning with the 1998 reporting year, facilities
may enter as many chemicals as are eligible on a
single Form A.
Toxics Release Inventory Reporting Forms and Instructions 79
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F. Instructions for Completing
EPA Form A
For all parts of Form A:
• You should type or print information on the
form in the format requested and use black ink.
(Using blue ink for the certification signature is
suggested as a means of indicating its
originality.)
• All information on the Form A is required.
• Do not leave items in Parts I and II on the
Form A blank unless specifically directed to do
so; if an item does not apply to you, you should
enter NA in the space provided. If your
information does not fill all the spaces
provided for a type of information, enter NA,
in the next blank space in the sequence.
• Do not submit an incomplete form. The
certification statement (Part I, Section 3)
specifies that the report is complete as
submitted. See Page 1 of these instructions for
the definition of a complete submission.
Part L Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported
information applies, not the year in which you are
submitting the report. Information for the reporting
year 2009 must be submitted on or before July 1,
2010.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313
chemical identified on Page 3 a trade
secret?
If facilities wish to report more than one eligible
chemical on the same Form A, then they are not
able to make trade secrecy claims. Any trade
secrecy claims should be made on a separate form,
and then the process is the same as using the Form
R and as described in the following instructions.
The specific identity of the EPCRA Section 313
chemical being reported in Part II, Section 1, may
be designated as a trade secret. If you are making a
trade secret claim, mark "yes" and proceed to
Section 2.2. Only check "yes" if you manufacture,
process, or otherwise use the EPCRA Section 313
chemical whose identity is a trade secret. (See Page
3 of these instructions for specific information on
trade secrecy claims.) If you checked "no," proceed
to Section 3; do not answer Section 2.2.
Do not submit trade secret reports
electronically. See last year's Reporting
Forms and Instructions.
2.2 If "yes" in 2.1, is this copy sanitized or
unsanitized?
You should check "sanitized" if this copy of the
report is the public version that does not contain
the EPCRA Section 313 chemical identity but does
contain a generic name that is structurally
descriptive in its place, and you have claimed the
EPCRA Section 313 chemical identity trade secret
in Part I, Section 2.1. Otherwise, check
"unsanitized."
Section 3. Certification
The Form A must be signed by a senior official
with management responsibility for the person (or
persons) completing the form. A senior
management official must certify the accuracy and
completeness of the information reported on the
form by signing and dating the Form A. Each
report must contain an original signature. Unlike
the certification statement contained on Form R,
the certification statement provided on the
Alternate Threshold Form A pertains to the
facility's eligibility of having met the conditions as
described in 40 CFR Section 372.27. You should
print or type in the space provided the name and
title of the person who signs the statement. This
certification statement applies to all the
information supplied on the form and should be
signed only after the form has been completed.
Failure to certify submissions will lead to a Notice
of Non-Compliance. Please see Appendix C.2
Levels of Errors Identified in FDPs.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI
Facility Identification Number
Enter the full name that the facility presents to the
public and its customers in doing business (e.g., the
name that appears on invoices, signs, and other
official business documents). Do not use a
nickname for the facility (e.g., Main Street Plant)
unless that is the legal name of the facility under
which it does business. Also enter the street
address, mailing address, city, county, state, and
zip code in the space provided. Do not use a post
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on EPA Form A Certification Statement
office box number as the street address. The street
address provided must be the location where the
EPCRA Section 313 chemicals are manufactured,
processed, or otherwise used. If your mailing
address and street address are the same, you should
enter NA in the space for the mailing address.
If your facility is not in a county, put the name of
your city, district (for example District of
Columbia), or parish (if you are in Louisiana) in
the county block of the Form R and Form A as well
as in the County field of TRI-MEweb . "NA" or
"None" are not acceptable entries.
If you have submitted a Form A or Form R for
previous reporting years, a TRI Facility
Identification Number has been assigned to your
facility. If you know your TRI Facility
Identification Number, complete Section 4. If you
do not know your TRI Facility Identification
Number, contact the CDX Help Desk toll free at 1-
888-890-1995. If your facility has moved, do not
enter your TRI facility identification number, you
should enter "New Facility."
The TRI Facility Identification Number is
established by the first Form R submitted by a
facility at a particular location. This identification
number is retained by the facility even if the
facility changes name, ownership, production
processes, SIC or NAICS codes, etc. This
identification number will stay with this location. If
a new facility moves to this location it should use
this TRI Facility Identification Number.
Establishments of a facility that report separately
should use the TRI Facility Identification Number
of the facility.
You should enter "New Facility" in the space for
the TRI Facility Identification number if this is
your first submission.
4.2 Federal Facility Designation
Executive Order 13423 directs federal facilities to
comply with Right-To-Know Laws and Pollution
Prevention Requirements. Please indicate in 4.2A.
if the reporting facility is a federal facility or in
4.2.B if the submitter is a contractor at a federal
facility (GOCO). If the reporting facility is not a
federal facility, you should leave this space blank.
Form R allows a facility to report multiple
submissions for the same chemical if the facility is
composed of several distinct establishments. This
data element provides the option of reporting full
or partial facility information on Form R, however,
this is not applicable for those facilities taking
advantage of the Alternate Threshold and Form A.
4.3 Technical Contact
Enter the name and telephone number (including
area code) of a technical representative whom EPA
or state officials may contact for clarification of the
information reported on Form A. You should also
enter an email address for this person. EPA
encourages facilities to provide an email address
for its Technical Contact on their TRI submissions
because they will be able to receive important
program updates and email alerts notifying them
when their FDP has been updated and is available
on the FDP website. If the technical contact does
not have an email address you should enter NA.
This contact person does not have to be the same
person who prepares the report or signs the Form A
and does not necessarily need to be someone at the
location of the reporting facility. However, this
person should be familiar with the details of the
report so that he or she can answer questions about
the information provided.
4.4 Public Contact
Enter the name and telephone number (including
area code) of a person who can respond to
questions from the public about the form. You
should also enter an e-mail address for this person.
If you choose to designate the same person as both
the Technical and the Public Contact, or you do not
have a Public Contact, you may enter "Same as
Section 4.3" in this space. This contact person does
not have to be the same person who prepares the
form or signs the Certification Statement and does
not necessarily need to be someone at the location
of the reporting facility.
4.5 North American Industry Classification
System (NAICS) Code
Enter the appropriate six digit North American
Industry Classification System (NAICS) Code that
is the primary NAICS Code for your facility in
Section 4.5(a). (Use 2007 NAICS codes.) Enter
any other applicable NAICS for your facility in 4.5
(b)-(f). The tables in Section B list the required
NAICS codes and their exceptions/ limitations. If
you do not know your NAICS code, consult the
2007 NAICS Manual (see Section B.2 of these
Toxics Release Inventory Reporting Forms and Instructions
81
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instructions for ordering information) or check the
SIC to NAICS crosswalk tables at
http://www.census.gov.
The North American Industry Classification
System (NAICS) is the economic classification
system that replaces the 1987 SIC code system. A
Federal Register notice was published on June 6,
2006 (71 FR 32464). NAICS codes are required on
TRI reporting forms beginning with RY 2006. A
subsequent Federal Register notice was published
on June 9, 2008 (73 FR 32466) to incorporate 2007
OMB revisions and other corrections to the NAICS
codes used for TRI Reporting.
4.6 Dun & Bradstreet Number(s)
Enter the nine digit number assigned by D&B for
your facility or each establishment within your
facility. These numbers code the facility for
financial purposes. This number may be available
from your facility's treasurer or financial officer.
You can also obtain the numbers by calling 1-888-
814-1435 or visiting this web site:
https://www.dnb.com/product/dlw/form cc4.htm.
If a facility does not subscribe to the D&B service,
a number can be obtained, toll free at
1-800-234-3867 (8:00 AM to 6:00 PM, Local
Time) or on the Web at http://www.dnb.com. If
none of your establishments has been assigned a
D&B number, you should enter NA in box (a). If
only some of your establishments have been
assigned Dun & Bradstreet numbers, enter those
numbers in Part I, Section 4.6.
(meaning that none of the facility owners directly
owns at least 50 percent of the voting stock of the
facility at issue), the facility should provide the
name of the parent company of either the facility
operator or the owner with the largest ownership
interest in the facility. If neither the operator nor
this owner has a parent company, then the NA box
should be checked.
5.1 Name of Parent Company
Enter the name of the corporation or other business
entity that is your ultimate US parent company. If
your facility has no parent company, you should
check the NA box.
5.2 Parent Company's Dun & Bradstreet
Number
Enter the D&B number for your ultimate US parent
company, if applicable. The number may be
obtained from the treasurer or financial officer of
the company or you may call 1-888-814-1435 or
visit this web site:
https://www.dnb.com/product/dlw/form cc4 .htm.
If your parent company does not have a D&B
number, you should check the NA box.
Section 5.
Parent Company
Information
You must provide information on your parent
company. For purposes of the Form A, a parent
company is defined as the highest level company,
located in the United States, that directly owns at
least 50 percent of the voting stock of your
company. If your facility is owned by a foreign
entity, you should enter NA in this space.
Corporate names should be treated as parent
company names for companies with multiple
facility sites. For example, the Bestchem
Corporation is not owned or controlled by any
other corporation but has sites throughout the
country whose names begin with Bestchem. In this
case, Bestchem Corporation should be listed as the
parent company. Note that a facility that is a 50:50
joint venture is its own parent company. When a
facility is owned by more than one company and
there is no parent company for the entire facility
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Facility Eligibility Determination for Alternate Threshold
and for Reporting on EPA Form A Certification Statement
Part II. Chemical Identification
Reporting on the Alternate Threshold Form A
Certification Statement for metals, metal category
compounds, and mixed isomers differs somewhat
from Form R reporting. Please refer to Section E.7
for these guidelines.
Section 1. Toxic Chemical Identity
(Important: DO NOT complete this section if you
completed Section 2 of Part II below.)
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS)
registry number in Section 1.1 exactly as it appears
in Table II of these instructions for the chemical
being reported. CAS numbers are cross-referenced
with an alphabetical list of chemical names in
Table II. If you are reporting one of the EPCRA
Section 313 chemical categories (e.g., chromium
compounds), you should enter the applicable
category code in the CAS number space. EPCRA
Section 313 chemical category codes are listed
below and can also be found in Table He and
Appendix B.I.
EPCRA Section 313 Chemical Category Codes:
NO 10 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds*
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds (water dissociable;
reportable only when in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (CIO to C13)
N590 Poly cyclic aromatic compounds (PACs)
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
* Facilities cannot take the alternate threshold for
chemicals and chemical categories listed as PBT
chemicals.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form A and
unsanitized substantiation form. Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include a generic name that is structurally
descriptive in Part II, Section 1.3 of your sanitized
Form A.
1.2 EPCRA Section 313 Chemical or
Chemical Category Name
Enter the name of the EPCRA Section 313
chemical or chemical category exactly as it appears
in Table II. If the EPCRA Section 313 chemical
name is followed by a synonym in (parentheses),
report the chemical by the name that directly
follows the CAS number (i.e., not the synonym). If
the EPCRA Section 313 chemical identity is
actually a product trade name (e.g., dicofol), the
9th Collective Index name is listed below it in
brackets. You may report either name in this case.
Do not list the name of a chemical that does not
appear in Table II, such as individual members of
an EPCRA Section 313 chemical category. For
example, if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category
code N740.
If you are making a trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity on your unsanitized Form A and
unsanitized substantiation form. Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include a generic name in Part II, Section 1.3 of
your sanitized Form A.
Toxics Release Inventory Reporting Forms and Instructions
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1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form A. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to
seventy characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section 1.3; see Section 2 below.
In house plant codes and other substitute names
that are not structurally descriptive of the EPCRA
Section 313 chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both sanitized
and unsanitized Form A, and the name must be the
same as that used on your substantiation forms.
Section 2. Mixture Component
Identity
Report the generic name provided to you by your
supplier in this section if your supplier is claiming
the chemical identity proprietary or trade secret.
Do not answer "yes" in Part I, Section 2.1 on Page
1 of the form if you complete this section. You do
not need to supply trade secret substantiation forms
for this EPCRA Section 313 chemical because it is
your supplier who is claiming the chemical identity
a trade secret
2.1 Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this section
only if the following three conditions apply:
1. You determine that the mixture contains an
EPCRA Section 313 chemical but the only
identity you have for that chemical is a
generic name;
2. You know either the specific concentration of
that EPCRA Section 313 chemical component
or a maximum or average concentration level;
and
3. You multiply the concentration level by the
total annual amount of the whole mixture
processed or otherwise used and determine
that you meet the process or otherwise use
threshold for that single, generically identified
mixture component.
84
Toxics Release Inventory Reporting Forms and Instructions
-------
Facility Eligibility Determination for Alternate Threshold
and for Reporting on EPA Form A Certification Statement
Index
Ancillary or other use, 38
article component, 37
byproduct, 37
Catastrophic Events, 67, 69
CD, 1
CDX, vii, 2, 6, 83
chemical processing aid, 38
Coal Extraction Activities Exemption, 20
Coincidental Manufacture, 11, 12
Container Residue, 52
De Minimis Exemption, 16
Discharges to Receiving Streams or Water
Bodies, 41
Disposal to Land, 42
Dun & Bradstreet, 34, 84
Energy Recovery, 54, 57, 61, 62, 64
EPA Identification Number, 49, 50
EPCRA, vi, vii, viii, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11,
12, 13, 14, 15, 16, 17, 18, 20, 21, 22, 23, 24, 25,
26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38,
39, 40, 41, 42, 43, 44, 45, 46, 48, 49, 50, 51, 52,
53, 54, 57, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68,
69, 70, 72, 73, 74, 75, 80, 82, 85, 86
Facility Identification, 82
Form A, 79
formulation component, 37
Fugitive or Non-Point Air Emissions, 41
Full-Time Employee, 7
Import, 37
impurity, 37
Laboratory Activities Exemption, 20
Manufacture, 11, 13, 18, 20, 37
manufacturing aid, 38
Metal Category Compounds, 24
Metal Mining Overburden Exemption, 21
Mixture Component Identity, 27
Nitrate Compounds, 26
On-Site Recycling Codes, 62
Other Disposal, 43
Other Surface Impoundments, 43
Otherwise Use, 11, 13, 15, 18, 37
PBT, 8, 13, 14, 15, 16, 17, 18, 21, 22, 23, 25, 28,
29, 30, 31, 36, 39, 40, 41, 43, 48, 49, 50, 51, 62,
64,68
Process, 4, 11, 13, 18,37
Produce, 37
Production Ratio, 71
RCRA Subtitle C landfills, 42
RCRA Subtitle C Surface Impoundments, 43
reactant, 37
Repackaging, 37
Reporting Year, 28, 29, 30, 31, 65
Revise, 4
sale/distribution, 37
Source Reduction, 64, 74
Storm water Runoff, 48
Submit Paper Form R, 2
Surface Impoundments, 43
Technical Contact, 6, 33, 83
Threshold Determinations, 21
Total Transfers, 49
Toxics Release Inventory Assistance Library
(TRIAL), vii
Trade Secret, 2, 32, 82
TRI-ME, vii, 1, 32, 83
Underground Injection, 42, 55
Waste Treatment Codes, 60
Withdraw, 4, 5
Toxics Release Inventory Reporting Forms and Instructions
85
-------
Table 1.NAICS Codes
1.1 NAICS codes that
correspond to SIC codes 20
through 39:
113310 Logging
311 Food Manufacturing
3111 Animal Food Manufacturing
31111 Animal Food Manufacturing
311111 Dog and Cat Food Manufacturing
311119 Other Animal Food Manufacturing (except
facilities primarily engaged in Custom Grain
Grinding for Animal Feed)
3112 Grain and Oilseed Milling
31121 Flour Milling and Malt
Manufacturing
311211 Flour Milling
311212 Rice Milling
311213 Malt Manufacturing
31122 Starch and Vegetable Fats and
Oils Manufacturing
311221 Wet Corn Milling
311222 Soybean Processing
311223 Other Oilseed Processing
311225 Fats and Oils Refining and Blending
31123 Breakfast Cereal Manuf.
311230 Breakfast Cereal Manufacturing
3113 Sugar and Confectionery
Product Manufacturing
31131 Sugar Manufacturing
311311 Sugarcane Mills
311312 Cane Sugar Refining
311313 Beet Sugar Manufacturing
31132 Chocolate and Confectionery
Manufacturing from Cacao
Beans
311320 Chocolate and Confectionery Manufacturing
from Cacao Beans
31133 Confectionery Manufacturing
from Purchased Chocolate
311330 Confectionery Manufacturing from Purchased
Chocolate (except facilities primarily
engaged in the retail sale of candy, nuts,
popcorn and other confections not for
immediate consumption made on the
premises)
31134 Nonchocolate Confectionery
Manufacturing
311340 Nonchocolate Confectionery Manufacturing
(except facilities primarily engaged in the
retail sale of candy, nuts, popcorn and other
confections not for immediate consumption
made on the premises)
3114 Fruit and Vegetable
Preserving and Specialty Food
Manufacturing
31141 Frozen Food Manufacturing
311412 Frozen Specialty Food Manufacturing
31142 Fruit and Vegetable Canning,
Pickling and Drying
311421 Fruit and Vegetable Canning
311422 Specialty Canning
311423 Dried and Dehydrated Food Manufacturing
3115 Dairy Product Manufacturing
31151 Dairy Product (except Frozen)
Manufacturing
311511 Fluid Milk Manufacturing
311512 Creamery Butter Manufacturing
311513 Cheese Manufacturing
311514 Dry, Condensed, and Evaporated Dairy
Product Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-1
-------
Table I. NAICS Codes
31152 Ice Cream and Frozen Dessert
Manufacturing
311520 Ice Cream and Frozen Dessert Manufacturing
3116 Animal Slaughtering and
Processing
31161 Animal Slaughtering and
Processing
311611 Animal (except Poultry) Slaughtering (except
for facilities primarily engaged in Custom
Slaughtering for individuals)
311612 Meat Processed from Carcasses [except for
facilities primarily engaged in the cutting up
and resale of purchased fresh carcasses for the
trade (including boxed beef)]
311613 Rendering and Meat Byproduct Processing
311615 Poultry Processing
3117 Seafood Product Preparation
and Packaging
311711 Seafood Canning
311712 Fresh and Frozen Seafood Processing
3118 Bakeries and Tortilla
Manufacturing
31181 Bread and Bakery Product
Manufacturing
311812 Commercial Bakeries
311813 Frozen Cakes, Pies, and Other Pastries
Manufacturing
31182 Cookie, Cracker, and Pasta
Manufacturing
311821 Cookie and Cracker Manufacturing
311822 Flour Mixes and Dough Manufacturing from
Purchased Flour
311823 Dry Pasta Manufacturing
31183 Tortilla Manufacturing
311830 Tortilla Manufacturing
3119 Other Food Manufacturing
31191 Snack Food Manufacturing
311911 Roasted Nuts and Peanut Butter
Manufacturing
311919 Other Snack Food Manufacturing
31192 Coffee and Tea
Manufacturing
311920 Coffee and Tea Manufacturing
31193 Flavoring Syrup and
Concentrate Manufacturing
311930 Flavoring Syrup and Concentrate
Manufacturing
31194 Seasoning and Dressing
Manufacturing
311941 Mayonnaise, Dressing, and Other Prepared
Sauce Manufacturing
311942 Spice and Extract Manufacturing
31199 All Other Miscellaneous Food
Manufacturing
311991 Perishable Prepared Food Manufacturing
311999 All Other Miscellaneous Food
Manufacturing
312 Beverage and Tobacco
Product Manufacturing
3121 Beverage Manufacturing
31211 Soft Drink and Ice
Manufacturing
312111 Soft Drink Manufacturing
312112 Bottled Water Manufacturing (except
facilities primarily engaged in bottling
mineral or spring water)
312113 Ice Manufacturing
31212 Breweries
312120 Breweries
31213 Wineries
312130 Wineries
31214 Distilleries
312140 Distilleries
1-2
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
3122 Tobacco Manufacturing
31221 Tobacco Stemming and
Redrying
312210 Tobacco Stemming and Redrying
31222 Tobacco Product
Manufacturing
312221 Cigarette Manufacturing
312229 Other Tobacco Product Manufacturing
(except for facilities primarily engaged in
providing Tobacco Sheeting Services)
313 Textile Mills
3131 Fiber, Yarn, and Thread
Mills
31311 Fiber, Yarn, and Thread
Mills
313111 Yarn Spinning Mills
313112 Yarn Texturizing, Throwing, and Twisting
Mills
313113 Thread Mills
3132 Fabric Mills
31321 Broadwoven Fabric Mills
313210 Broadwoven Fabric Mills
31322 Narrow Fabric Mills and
Schiffli Machine Embroidery
313221 Narrow Fabric Mills
313222 Schiffli Machine Embroidery
31323 Nonwoven Fabric Mills
313230 Nonwoven Fabric Mills
31324 Knit Fabric Mills
313241 Weft Knit Fabric Mills
313249 Other Knit Fabric and Lace Mills
3133 Textile and Fabric Finishing
and Fabric Coating Mills
31331
313311
313312
31332
313320
314
3141
31411
314110
31412
314121
314129
3149
31491
314911
314912
31499
314991
314992
314999
315
Textile and Fabric Finishing
Mills
Broadwoven Fabric Finishing Mills (except
facilities primarily engaged in converting
broadwoven piece goods and broadwoven
textiles and facilities primarily engaged in
sponging fabric for tailors and dressmakers)
Textile and Fabric Finishing (except
Broadwoven Fabric) Mills (except facilities
primarily engaged in converting narrow
woven textiles and narrow woven piece
goods)
Fabric Coating Mills
Fabric Coating Mills
Textile Product Mills
Textile Furnishing Mills
Carpet and Rug Mills
Carpet and Rug Mills
Curtain and Linen Mills
Curtain and Drapery Mills (except facilities
primarily engaged in making custom drapery
for retail sale)
Other Household Textile Product Mills
(except facilities primarily engaged in making
custom drapery for retail sale)
Other Textile Product Mills
Textile Bag and Canvas Mills
Textile Bag Mills
Canvas and Related Product Mills
All Other Textile Product
Mills
Rope, Cordage, and Twine Mills
Tire Cord and Tire Fabric Mills
All Other Miscellaneous Textile Product
Mills (except facilities engaged in binding
carpets and rugs for the trade, carpet cutting
and binding, and embroidering on textile
products (except apparel) for the trade)
Apparel Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-3
-------
Table I. NAICS Codes
3151
31511
315111
315119
31519
315191
315192
3152
31521
315211
315212
31522
315221
315222
315223
315224
315225
315228
31523
315231
315232
Apparel Knitting Mills
Hosiery and Sock Mills
•7
Sheer Hosiery Mills
Other Hosiery and Sock Mills
Other Apparel Knitting Mills
Outerwear Knitting Mills
Underwear and Nightwear Knitting Mills
Cut and Sew Apparel
Manufacturing
Cut and Sew Apparel
Contractors
Men's and Boys' Cut and Sew Apparel
Contractors
Women's, Girls', and Infants' Cut and Sew
Apparel Contractors
Men's and Boys' Cut and Sew
«/
Apparel Manufacturing
Men's and Boys' Cut and Sew Underwear
and Nightwear Manufacturing
Men's and Boys' Cut and Sew Suit, Coat, and
Overcoat Manufacturing (except custom
tailors primarily engaged in making and
selling men's and boy's suits, cut and sewn
from purchased fabric)
Men's and Boys' Cut and Sew Shirt (except
Work Shirt) Manufacturing (except custom
tailors primarily engaged in making and
selling men's and boy's dress shirts, cut and
sewn from purchased fabric)
Men's and Boys' Cut and Sew Trouser,
Slack, and Jean Manufacturing
Men's and Boys' Cut and Sew Work Clothing
Manufacturing
Men's and Boys' Cut and Sew Other
Outerwear Manufacturing
Women's and Girls' Cut and
Sew Apparel Manufacturing
Women's and Girls' Cut and Sew Lingerie,
Loungewear, and Nightwear Manufacturing
Women's and Girls' Cut and Sew Blouse and
Shirt Manufacturing
315233
315234
315239
31529
315291
315292
315299
3159
31599
315991
315992
315993
315999
316
3161
31611
316110
3162
31621
316211
316212
316213
Women's and Girls' Cut and Sew Dress
Manufacturing (except custom tailors
primarily engaged in making and selling
bridal dresses or gowns, or women's, misses'
and girls' dresses cut and sewn from
purchased fabric (except apparel contractors)
(custom dressmakers)
Women's and Girls' Cut and Sew Suit, Coat,
Tailored Jacket, and Skirt Manufacturing
Women's and Girls' Cut and Sew Other
Outerwear Manufacturing
Other Cut and Sew Apparel
Manufacturing
Infants' Cut and Sew Apparel Manufacturing
Fur and Leather Apparel Manufacturing
All Other Cut and Sew Apparel
Manufacturing
Apparel Accessories and
Other Apparel Manufacturing
Apparel Accessories and
Other Apparel Manufacturing
Hat, Cap, and Millinery Manufacturing
Glove and Mitten Manufacturing
Men's and Boys' Neckwear Manufacturing
Other Apparel Accessories and Other Apparel
Manufacturing
Leather and Allied Product
Manufacturing
Leather and Hide Tanning
and Finishing
Leather and Hide Tanning
and Finishing
Leather and Hide Tanning and Finishing
Footwear Manufacturing
Footwear Manufacturing
Rubber and Plastics Footwear Manufacturing
House Slipper Manufacturing
Men's Footwear (except Athletic)
Manufacturing
1-4
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
316214 Women's Footwear (except Athletic)
Manufacturing
316219 Other Footwear Manufacturing
3169 Other Leather and Allied
Product Manufacturing
31699 Other Leather and Allied
Product Manufacturing
316991 Luggage Manufacturing
316992 Women's Handbag and Purse Manufacturing
316993 Personal Leather Good (except Women's
Handbag and Purse) Manufacturing
316999 All Other Leather Good Manufacturing
321 Wood Product Manufacturing
3211 Sawmills and Wood
Preservation
321113 Sawmills
321114 Wood Preservation
3212 Veneer, Plywood, and
Engineered Wood Product
Manufacturing
32121 Veneer, Plywood, and
Engineered Wood Product
Manufacturing
321211 Hardwood Veneer and Plywood
Manufacturing
321212 Softwood Veneer and Plywood
Manufacturing
321213 Engineered Wood Member (except Truss)
Manufacturing
321214 Truss Manufacturing
321219 Reconstituted Wood Product Manufacturing
3219 Other Wood Product
Manufacturing
32191 Millwork
321911 Wood Window and Door Manufacturing
321912 Cut Stock, Resawing Lumber, and Planing
321918 Other Millwork (including Flooring)
32192 Wood Container and Pallet
Manufacturing
321920 Wood Container and Pallet Manufacturing
32199 All Other Wood Product
Manufacturing
321991 Manufactured Home (Mobile Home)
Manufacturing
321992 Prefabricated Wood Building Manufacturing
321999 All Other Miscellaneous Wood Product
Manufacturing
322 Paper Manufacturing
3221 Pulp, Paper, and Paperboard
Mills
32211 Pulp Mills
322110 Pulp Mills
32212 Paper Mills
322121 Paper (except Newsprint) Mills
322122 Newsprint Mills
32213 Paperboard Mills
322130 Paperboard Mills
3222 Converted Paper Product
Manufacturing
32221 Paperboard Container
Manufacturing
322211 Corrugated and Solid Fiber Box
Manufacturing
322212 Folding Paperboard Box Manufacturing
322213 Setup Paperboard Box Manufacturing
322214 Fiber Can, Tube, Drum, and Similar Products
Manufacturing
322215 Nonfolding Sanitary Food Container
Manufacturing
32222 Paper Bag and Coated and
Treated Paper Manufacturing
322221 Coated and Laminated Packaging Paper and
Plastics Film Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-5
-------
Table I. NAICS Codes
322222 Coated and Laminated Paper Manufacturing
322223 Plastics, Foil, and Coated Paper Bag
Manufacturing
322224 Uncoated Paper and Multiwall Bag
Manufacturing
322225 Laminated Aluminum Foil Manufacturing for
Flexible Packaging Uses
322226 Surface-Coated Paperboard Manufacturing
32223 Stationery Product
Manufacturing
322231 Die-Cut Paper and Paperboard Office
Supplies
Manufacturing
322232 Envelope Manufacturing
322233 Stationery, Tablet, and Related Product
Manufacturing
32229 Other Converted Paper
Product Manufacturing
322291 Sanitary Paper Product Manufacturing
322299 All Other Converted Paper Product
Manufacturing
323 Printing and Related Support
Activities
3231 Printing and Related Support
Activities
32311 Printing
323110 Commercial Lithographic Printing
323113 Commercial Screen Printing
323114 Quick Printing (except facilities primarily
engaged in reproducing text, drawings, plans,
maps, or other copy by blueprinting,
photocopying, mimeographing, or other
methods of duplication other than printing or
microfilming (i.e., instant printing)
323115 Digital Printing
323116 Manifold Business Forms Printing
323117 Books Printing
323118 Blankbook, Looseleaf Binders, and Devices
Manufacturing
323119 Other Commercial Printing
32312 Support Activities for Printing
323121 Tradebinding and Related Work
323122 Prepress Services
324 Petroleum and Coal Products
Manufacturing
3241 Petroleum and Coal Products
Manufacturing
32411 Petroleum Refineries
324110 Petroleum Refineries
32412 Asphalt Paving, Roofing, and
Saturated Materials
Manufacturing
324121 Asphalt Paving Mixture and Block
Manufacturing
324122 Asphalt Shingle and Coating Materials
Manufacturing
32419 Other Petroleum and Coal
Products Manufacturing
324191 Petroleum Lubricating Oil and Grease
Manufacturing
324199 All Other Petroleum and Coal Products
Manufacturing
325 Chemical Manufacturing
3251 Basic Chemical
Manufacturing
32511 Petrochemical Manufacturing
325110 Petrochemical Manufacturing
32512 Industrial Gas Manufacturing
325120 Industrial Gas Manufacturing
32513 Synthetic Dye and Pigment
Manufacturing
325131 Inorganic Dye and Pigment Manufacturing
325132 Synthetic Organic Dye and Pigment
Manufacturing
32518 Other Basic Inorganic
Chemical Manufacturing
1-6
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
325181 Alkalies and Chlorine Manufacturing
325182 Carbon Black Manufacturing
325188 All Other Basic Inorganic Chemical
Manufacturing
32519 Other Basic Organic Chemical
Manufacturing
325191 Gum and Wood Chemical Manufacturing
325192 Cyclic Crude and Intermediate Manufacturing
325193 Ethyl Alcohol Manufacturing
325199 All Other Basic Organic Chemical
Manufacturing
3252 Resin, Synthetic Rubber, and
Artificial Synthetic Fibers and
Filaments Manufacturing
32521 Resin and Synthetic Rubber
Manufacturing
325211 Plastics Material and Resin Manufacturing
325212 Synthetic Rubber Manufacturing
32522 Artificial and Synthetic Fibers
and Filaments Manufacturing
325221 Cellulosic Organic Fiber Manufacturing
325222 Noncellulosic Organic Fiber Manufacturing
3253 Pesticide, Fertilizer, and Other
Agricultural Chemical
Manufacturing
32531 Fertilizer Manufacturing
325311 Nitrogenous Fertilizer Manufacturing
325312 Phosphatic Fertilizer Manufacturing
325314 Fertilizer (Mixing Only) Manufacturing
32532 Pesticide and Other
Agricultural Chemical
Manufacturing
325320 Pesticide and Other Agricultural Chemical
Manufacturing
3254 Pharmaceutical and Medicine
Manufacturing
32541 Pharmaceutical and Medicine
Manufacturing
325411 Medicinal and Botanical Manufacturing
325412 Pharmaceutical Preparation Manufacturing
325413 In-Vitro Diagnostic Substance Manufacturing
325414 Biological Product (except Diagnostic)
Manufacturing
3255 Paint, Coating, and Adhesive
Manufacturing
32551 Paint and Coating
Manufacturing
325510 Paint and Coating Manufacturing
32552 Adhesive Manufacturing
325520 Adhesive Manufacturing
3256 Soap, Cleaning Compound,
and Toilet Preparation
Manufacturing
32561 Soap and Cleaning Compound
Manufacturing
325611 Soap and Other Detergent Manufacturing
325612 Polish and Other Sanitation Good
Manufacturing
'325613 Surface Active Agent Manufacturing
32562 Toilet Preparation
Manufacturing
325620 Toilet Preparation Manufacturing
3259 Other Chemical Product and
Preparation Manufacturing
32591 Printing Ink Manufacturing
325910 Printing Ink Manufacturing
32592 Explosives Manufacturing
325920 Explosives Manufacturing
32599 All Other Chemical Product
and Preparation
Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-7
-------
Table I. NAICS Codes
325991 Custom Compounding of Purchased Resins
325992 Photographic Film, Paper, Plate, and
Chemical
Manufacturing
325998 All Other Miscellaneous Chemical Product
and Preparation Manufacturing (except
facilities primarily engaged in Aerosol can
filling on a job order or contract Basis)
326 Plastics and Rubber Products
Manufacturing
3261 Plastics Product
Manufacturing
32611 Plastics Packaging Materials
and Unlaminated Film and
Sheet Manufacturing
326111 Plastics Bag Manufacturing
326112 Plastics Packaging Film and Sheet (including
Laminated) Manufacturing
326113 Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
32612 Plastics, Pipe, Pipe Fitting, and
Unlaminated Profile Shape
Manufacturing
326121 Unlaminated Plastics Profile Shape
Manufacturing
326122 Plastics Pipe and Pipe Fitting Manufacturing
32613 Laminated Plastics Plate,
Sheet
(except Packaging), and Shape
Manufacturing
326130 Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
32614 Polystyrene Foam Product
Manufacturing
326140 Polystyrene Foam Product Manufacturing
32615 Urethane and Other Foam
Product (except Polystyrene)
Manufacturing
326150 Urethane and Other Foam Product (except
Polystyrene) Manufacturing
32616 Plastics Bottle Manufacturing
326160 Plastics Bottle Manufacturing
32619 Other Plastics Product
Manufacturing
326191 Plastics Plumbing Fixture Manufacturing
326192 Resilient Floor Covering Manufacturing
326199 All Other Plastics Product Manufacturing
3262 Rubber Product
Manufacturing
32621 Tire Manufacturing
326211 Tire Manufacturing (except Retreading)
32622 Rubber and Plastics Hoses and
Belting Manufacturing
326220 Rubber and Plastics Hoses and Belting
Manufacturing
32629 Other Rubber Product
Manufacturing
326291 Rubber Product Manufacturing for
Mechanical Use
326299 All Other Rubber Product Manufacturing
327 Nonmetallic Mineral Product
Manufacturing
3271 Clay Product and Refractory
Manufacturing
32711 Pottery, Ceramics, and
Plumbing Fixture
Manufacturing
327111 Vitreous China Plumbing Fixture and China
and Earthenware Bathroom Accessories
Manufacturing
327112 Vitreous China, Fine Earthenware, and Other
Pottery Product Manufacturing (except
facilities primarily engaged in manufacturing
and selling pottery on site)
327113 Porcelain Electrical Supply Manufacturing
1-8
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
32712 Clay Building Material and
Refractories Manufacturing
327121 Brick and Structural Clay Tile Manufacturing
327122 Ceramic Wall and Floor Tile Manufacturing
327123 Other Structural Clay Product Manufacturing
327124 Clay Refractory Manufacturing
327125 Nonclay Refractory Manufacturing
3272 Glass and Glass Product
Manufacturing
32721 Glass and Glass Product
Manufacturing
327211 Flat Glass Manufacturing
327212 Other Pressed and Blown Glass and
Glassware Manufacturing
327213 Glass Container Manufacturing
327215 Glass Product Manufacturing Made of
Purchased Glass
3273 Cement and Concrete Product
Manufacturing
32731 Cement Manufacturing
327310 Cement Manufacturing
32732 Ready-Mix Concrete
Manufacturing
327320 Ready-Mix Concrete Manufacturing
32733 Concrete, Pipe, Brick, and
Block Manufacturing
327331 Concrete Block and Brick Manufacturing
327332 Concrete Pipe Manufacturing
32739 Other Concrete Product
Manufacturing
327390 Other Concrete Product Manufacturing
3274 Lime and Gypsum Product
Manufacturing
32741 Lime Manufacturing
327410 Lime Manufacturing
32742 Gypsum Product
Manufacturing
327420 Gypsum Product Manufacturing
3279 Other Nonmetallic Mineral
Product Manufacturing
32791 Abrasive Product
Manufacturing
327910 Abrasive Product Manufacturing
32799 All Other Nonmetallic Mineral
Product Manufacturing
327991 Cut Stone and Stone Product Manufacturing
327992 Ground or Treated Mineral and Earth
Manufacturing
327993 Mineral Wool Manufacturing
327999 All Other Miscellaneous Nonmetallic Mineral
Product Manufacturing
331 Primary Metal Manufacturing
3311 Iron and Steel Mills and
Ferroalloy Manufacturing
33111 Iron and Steel Mills and
Ferroalloy Manufacturing
331111 Iron and Steel Mills
331112 Electrometallurgical Ferroalloy Product
Manufacturing
3312 Steel Product Manufacturing
from Purchased Steel
33121 Iron and Steel Pipe and Tube
Manufacturing from
Purchased Steel
331210 Iron and Steel Pipe and Tube Manufacturing
from Purchased Steel
33122 Rolling and Drawing of
Purchased Steel
331221 Rolled Steel Shape Manufacturing
331222 Steel Wire Drawing
Toxics Release Inventory Reporting Form and Instructions
1-9
-------
Table I. NAICS Codes
3313 Alumina and Aluminum
Production and Processing
33131 Alumina and Aluminum
Production and Processing
331311 Alumina Refining
331312 Primary Aluminum Production
331314 Secondary Smelting and Alloying of
Aluminum
331315 Aluminum Sheet, Plate, and Foil
Manufacturing
331316 Aluminum Extruded Product Manufacturing
331319 Other Aluminum Rolling and Drawing
3314 Nonferrous Metal (except
Aluminum) Production and
Processing
33141 Nonferrous Metal (except
Aluminum) Smelting and
Refining
331411 Primary Smelting and Refining of Copper
331419 Primary Smelting and Refining of Nonferrous
Metal (except Copper and Aluminum)
33142 Copper Rolling, Drawing,
Extruding and Alloying
331421 Copper Rolling, Drawing, and Extruding
331422 Copper Wire (except Mechanical) Drawing
331423 Secondary Smelting, Refining, and Alloying
of Copper
33149 Nonferrous Metal (except
Copper and Aluminum)
Rolling, Drawing, Extruding,
and Alloying
331491 Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and Extruding
331492 Secondary Smelting, Refining, and Alloying
of
Nonferrous Metal (except Copper and
Aluminum)
3315 Foundries
33151 Ferrous Metal Foundries
331511 Iron Foundries
331512 Steel Investment Foundries
331513 Steel Foundries (except Investment)
33152 Nonferrous Metal Foundries
331521 Aluminum Die-Casting Foundries
3 31522 Nonferrous (except Aluminum) Die-Casting
Foundries
3 31524 Aluminum Foundries (except Die-Casting)
331525 Copper Foundries (except Die-Casting)
331528 Other Nonferrous Foundries (except Die-
Casting)
332 Fabricated Metal Product
Manufacturing
3321 Forging and Stamping
33211 Forging and Stamping
332111 Iron and Steel Forging
332112 Nonferrous Forging
332114 Custom Roll Forming
332115 Crown and Closure Manufacturing
332116 Metal Stamping
332117 Powder Metallurgy Part Manufacturing
3322 Cutlery and Handtool
Manufacturing
33221 Cutlery and Handtool
Manufacturing
332211 Cutlery and Flatware (except Precious)
Manufacturing
332212 Hand and Edge Tool Manufacturing
332213 Saw Blade and Handsaw Manufacturing
332214 Kitchen Utensil, Pot, and Pan Manufacturing
3323 Architectural and Structural
Metals Manufacturing
1-10
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
33231 Plate Work and Fabricated
Structural Product
Manufacturing
332311 Prefabricated Metal Building and Component
Manufacturing
332312 Fabricated Structural Metal Manufacturing
332313 Plate Work Manufacturing
33232 Ornamental and Architectural
Metal Products
Manufacturing
332321 Metal Window and Door Manufacturing
332322 Sheet Metal Work Manufacturing
332323 Ornamental and Architectural Metal Work
Manufacturing
3324 Boiler, Tank, and Shipping
Container Manufacturing
33241 Power Boiler and Heat
Exchanger Manufacturing
532410 Power Boiler and Heat Exchanger
Manufacturing
33242 Metal Tank (Heavy Gauge)
Manufacturing
332420 Metal Tank (Heavy Gauge) Manufacturing
33243 Metal Can, Box, and Other
Metal Container (Light
Gauge) Manufacturing
332431 Metal Can Manufacturing
332439 Other Metal Container Manufacturing
3325 Hardware Manufacturing
33251 Hardware Manufacturing
332510 Hardware Manufacturing
3326 Spring and Wire Product
Manufacturing
33261 Spring and Wire Product
Manufacturing
332611 Spring (Heavy Gauge) Manufacturing
332612 Spring (Light Gauge) Manufacturing
332618 Other Fabricated Wire Product
Manufacturing
3327 Machine Shops; Turned
Product; and Screw, Nut and
Bolt Manufacturing
33271 Machine Shops
332710 Machine Shops
33272 Turned Product and Screw,
Nut and Bolt Manufacturing
332721 Precision Turned Product Manufacturing
332722 Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
3328 Coating, Engraving, Heat
Treating, and Allied Activities
33281 Coating, Engraving, Heat
Treating, and Allied Activities
332811 Metal Heat Treating
332812 Metal Coating, Engraving (except Jewelry
and Silverware), and Allied Services to
Manufacturers
332813 Electroplating, Plating, Polishing, Anodizing,
and Coloring
3329 Other Fabricated Metal
Product Manufacturing
33291 Metal Valve Manufacturing
332911 Industrial Valve Manufacturing
332912 Fluid Power Valve and Hose Fitting
Manufacturing
332913 Plumbing Fixture Fitting and Trim
Manufacturing
332919 Other Metal Valve and Pipe Fitting
Manufacturing
33299 All Other Fabricated Metal
Product Manufacturing
332991 Ball and Roller Bearing Manufacturing
332992 Small Arms Ammunition Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-11
-------
Table I. NAICS Codes
332993 Ammunition (except Small Arms)
Manufacturing
332994 Small Arms Manufacturing
332995 Other Ordnance and Accessories
Manufacturing
332996 Fabricated Pipe and Pipe Fitting
Manufacturing
332997 Industrial Pattern Manufacturing
332998 Enameled Iron and Metal Sanitary Ware
Manufacturing
332999 All Other Miscellaneous Fabricated Metal
Product Manufacturing
333 Machinery Manufacturing
3331 Agriculture, Construction, and
Mining Machinery
Manufacturing
33311 Agricultural Implement
Manufacturing
333111 Farm Machinery and Equipment
Manufacturing
333112 Lawn and Garden Tractor and Home Lawn
and Garden Equipment Manufacturing
33312 Construction Machinery
Manufacturing
333120 Construction Machinery Manufacturing
33313 Mining and Oil and Gas Field
Machinery Manufacturing
333131 Mining Machinery and Equipment
Manufacturing
333132 Oil and Gas Field Machinery and Equipment
Manufacturing
3332 Industrial Machinery
Manufacturing
33321 Sawmill and Woodworking
Machinery Manufacturing
333210 Sawmill and Woodworking Machinery
Manufacturing
33322 Plastics and Rubber Industry
Machinery Manufacturing
333220 Plastics and Rubber Industry Machinery
Manufacturing
33329 Other Industrial Machinery
Manufacturing
333291 Paper Industry Machinery Manufacturing
333292 Textile Machinery Manufacturing
333293 Printing Machinery and Equipment
Manufacturing
333294 Food Product Machinery Manufacturing
333295 Semiconductor Machinery Manufacturing
333298 All Other Industrial Machinery
Manufacturing
3333 Commercial and Service
Industry Machinery
Manufacturing
33331 Commercial and Service
Industry Machinery
Manufacturing
333311 Automatic Vending Machine Manufacturing
333312 Commercial Laundry, Drycleaning, and
Pressing Machine Manufacturing
333313 Office Machinery Manufacturing
333314 Optical Instrument and Lens Manufacturing
333315 Photographic and Photocopying Equipment
Manufacturing
333319 Other Commercial and Service Industry
Machinery Manufacturing
3334 Ventilation, Heating, Air-
Conditioning, and Commercial
Refrigeration
33341 Equipment Manufacturing
Ventilation, Heating, Air-
Conditioning, and Commercial
Refrigeration Equipment
Manufacturing
333411 Air Purification Equipment Manufacturing
1-12
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
333412 Industrial and Commercial Fan and Blower
Manufacturing
333414 Heating Equipment (except Warm Air
Furnaces) Manufacturing
333415 Air-Conditioning and Warm Air Heating
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
3335 Metalworking Machinery
Manufacturing
33351 Metalworking Machinery
Manufacturing
333511 Industrial Mold Manufacturing
333512 Machine Tool (Metal Cutting Types)
Manufacturing
333513 Machine Tool (Metal Forming Types)
Manufacturing
333514 Special Die and Tool, Die Set, Jig, and
Fixture Manufacturing
333515 Cutting Tool and Machine Tool Accessory
Manufacturing
333516 Rolling Mill Machinery and Equipment
Manufacturing
333518 Other Metalworking Machinery
Manufacturing
3336 Engine, Turbine, and Power
Transmission Equipment
Manufacturing
33361 Engine, Turbine, and Power
Transmission Equipment
Manufacturing
333611 Turbine and Turbine Generator Set Units
Manufacturing
333612 Speed Changer, Industrial High-Speed Drive,
and Gear Manufacturing
333613 Mechanical Power Transmission Equipment
Manufacturing
33618 Other Engine Equipment Manufacturing
3339 Other General Purpose
Machinery Manufacturing
33391 Pump and Compressor
Manufacturing
333911 Pump and Pumping Equipment
Manufacturing
333912 Air and Gas Compressor Manufacturing
333913 Measuring and Dispensing Pump
Manufacturing
33392 Material Handling Equipment
Manufacturing
333921 Elevator and Moving Stairway Manufacturing
333922 Conveyor and Conveying Equipment
Manufacturing
333923 Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333924 Industrial Truck, Tractor, Trailer, and Stacker
Machinery Manufacturing
33399 All Other General Purpose
Machinery Manufacturing
333991 Power-Driven Handtool Manufacturing
3 3 3 992 Welding and Soldering Equipment
Manufacturing
333993 Packaging Machinery Manufacturing
3 3 3 994 Industrial Process Furnace and Oven
Manufacturing
333995 Fluid Power Cylinder and Actuator
Manufacturing
3 3 3 996 Fluid Power Pump and Motor Manufacturing
3 3 3 997 Scale and Balance Manufacturing
333999 All Other Miscellaneous General Purpose
Machinery Manufacturing
334 Computer and Electronic
Product Manufacturing
3341 Computer and Peripheral
Equipment Manufacturing
33411 Computer and Peripheral
Equipment Manufacturing
334111 Electronic Computer Manufacturing
334112 Computer Storage Device Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-13
-------
Table I. NAICS Codes
334113
334119
3342
33421
334210
33422
334220
33429
334290
3343
33431
334310
3344
33441
334411
334412
334413
334414
334415
334416
Computer Terminal Manufacturing
Other Computer Peripheral Equipment
Manufacturing
Communications Equipment
Manufacturing
Telephone Apparatus
Manufacturing
Telephone Apparatus Manufacturing
Radio and Television
Broadcasting and Wireless
Communications Equipment
_E j.
Manufacturing
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
Other Communications
Equipment Manufacturing
Other Communications Equipment
A /I -C 4-
Manufacturing
Audio and Video Equipment
Manufacturing
Audio and Video Equipment
Manufacturing
Audio and Video Equipment Manufacturing
Semiconductor and Other
Electronic Component
Manufacturing
Semiconductor and Other
Electronic Component
Manufacturing
Electron Tube Manufacturing
Bare Printed Circuit Board Manufacturing
Semiconductor and Related Device
Manufacturing
Electronic Capacitor Manufacturing
Electronic Resistor Manufacturing
Electronic Coil, Transformer, and Other
Inductor Manufacturing
334417
334418
334419
3345
33451
334510
334511
334512
334513
334514
334515
334516
334517
334518
334519
3346
33461
334612
Electronic Connector Manufacturing
Printed Circuit Assembly (Electronic
Assembly) Manufacturing
Other Electronic Component Manufacturing
Navigational, Measuring,
Electro medical, and Control
Instruments Manufacturing
Navigational, Measuring,
Electro medical, and Control
Instruments Manufacturing
Electromedical and Electrotherapeutic
Apparatus Manufacturing
Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing
Automatic Environmental Control
Manufacturing for Residential, Commercial,
and Appliance Use
Instruments and Related Products
Manufacturing for Measuring, Displaying,
and Controlling Industrial Process Variables
Totalizing Fluid Meter and Counting Device
Manufacturing
Instrument Manufacturing for Measuring and
Testing Electricity and Electrical Signals
Analytical Laboratory Instrument
Manufacturing
Irradiation Apparatus Manufacturing
Watch, Clock, and Part Manufacturing
Other Measuring and Controlling Device
Manufacturing
Manufacturing and
Reproducing Magnetic and
Optical Media
Manufacturing and
Reproducing Magnetic and
Optical Media
Prerecorded Compact Disc (except Software),
Tape, and Record Reproducing (except
facilities primarily engaged in mass
reproducing pre-recorded Video Cassettes,
and mass reproducing Video tape or disk)
1-14
Toxics Release Inventory Reporting Form and Instructions
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Table I. NAICS Codes
334613 Magnetic and Optical Recording Media
Manufacturing
335 Electrical Equipment,
Appliance, and Component
Manufacturing
3351 Electric Lighting Equipment
Manufacturing
33511 Electric Lamp Bulb and Part
j.
Manufacturing
335110 Electric Lamp Bulb and Part Manufacturing
33512 Lighting Fixture
Manufacturing
335121 Residential Electric Lighting Fixture
Manufacturing
335122 Commercial, Industrial, and Institutional
Electric Lighting Fixture Manufacturing
335 129 Other Lighting Equipment Manufacturing
3352 Household Appliance
Manufacturing
33521 Small Electrical Appliance
Manufacturing
335211 Electric Housewares and Household Fan
Manufacturing
335212 Household Vacuum Cleaner Manufacturing
33522 Major Appliance
Manufacturing
3 3 522 1 Household Cooking Appliance
Manufacturing
3 3 5222 Household Refrigerator and Home Freezer
Manufacturing
3 3 5224 Household Laundry Equipment
Manufacturing
335228 Other Major Household Appliance
Manufacturing
3353 Electrical Equipment
Manufacturing
33531 Electrical Equipment
Manufacturing
335311 Power, Distribution, and Specialty
Transformer Manufacturing
335312 Motor and Generator Manufacturing (except
facilities primarily engaged in armature
rewinding on a factory basis)
335313 Switchgear and Switchboard Apparatus
Manufacturing
335314 Relay and Industrial Control Manufacturing
3359 Other Electrical Equipment
and Component
Manufacturing
33591 Battery Manufacturing
33591 1 Storage Battery Manufacturing
335912 Primary Battery Manufacturing
33592 Communication and Energy
Wire and Cable
Manufacturing
335921 Fiber Optic Cable Manufacturing
335929 Other Communication and Energy Wire
Manufacturing
33593 Wiring Device Manufacturing
335931 Current-Carrying Wiring Device
Manufacturing
335932 Noncurrent-Carrying Wiring Device
Manufacturing
33599 All Other Electrical
Equipment
and Component
Manufacturing
335991 Carbon and Graphite Product Manufacturing
335999 All Other Miscellaneous Electrical
Equipment and Component Manufacturing
336 Transportation Equipment
Manufacturing
3361 Motor Vehicle Manufacturing
33611 Automobile and Light Duty
Motor Vehicle Manufacturing
336111 Automobile Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-15
-------
Table I. NAICS Codes
336112 Light Track and Utility Vehicle
Manufacturing
33612 Heavy Duty Truck
Manufacturing
336120 Heavy Duty Track Manufacturing
3362 Motor Vehicle Body and
Trailer Manufacturing
33621 Motor Vehicle Body and
Trailer Manufacturing
336211 Motor Vehicle Body Manufacturing
336212 Track Trailer Manufacturing
336213 Motor Home Manufacturing
336214 Travel Trailer and Camper Manufacturing
3363 Motor Vehicle Parts
Manufacturing
33631 Motor Vehicle Gasoline
Engine and Engine Parts
Manufacturing
336311 Carburetor, Piston, Piston Ring, and Valve
Manufacturing
336312 Gasoline Engine and Engine Parts
Manufacturing
33632 Motor Vehicle Electrical and
Electronic Equipment
Manufacturing
336321 Vehicular Lighting Equipment Manufacturing
336322 Other Motor Vehicle Electrical and Electronic
Equipment Manufacturing
33633 Motor Vehicle Steering and
Suspension Components
(except Spring)
Manufacturing
336330 Motor Vehicle Steering and Suspension
Components (except Spring) Manufacturing
33634 Motor Vehicle Brake System
Manufacturing
336340 Motor Vehicle Brake System Manufacturing
33635 Motor Vehicle Transmission
and Power Train Parts
Manufacturing
336350 Motor Vehicle Transmission and Power Train
Parts Manufacturing
33636 Motor Vehicle Seating and
Interior Trim Manufacturing
336360 Motor Vehicle Seating and Interior Trim
Manufacturing
33637 Motor Vehicle Metal Stamping
336370 Motor Vehicle Metal Stamping
33639 Other Motor Vehicle Parts
Manufacturing
336391 Motor Vehicle Air-Conditioning
Manufacturing
336399 All Other Motor Vehicle Parts Manufacturing
3364 Aerospace Product and Parts
Manufacturing
33641 Aerospace Product and Parts
Manufacturing
336411 Aircraft Manufacturing
336412 Aircraft Engine and Engine Parts
Manufacturing
336413 Other Aircraft Parts and Auxiliary Equipment
Manufacturing
336414 Guided Missile and Space Vehicle
Manufacturing
336415 Guided Missile and Space Vehicle Propulsion
Unit and Propulsion Unit Parts Manufacturing
336419 Other Guided Missile and Space Vehicle
Parts and Auxiliary Equipment
Manufacturing
3365 Railroad Rolling Stock
Manufacturing
33651 Railroad Rolling Stock
Manufacturing
336510 Railroad Rolling Stock Manufacturing
3366 Ship and Boat Building
1-16
Toxics Release Inventory Reporting Form and Instructions
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Table I. NAICS Codes
33661
336611
336612
3369
33699
336991
336992
336999
337
3371
33711
337110
33712
337121
337122
337124
337125
Ship and Boat Building
Ship Building and Repairing
Boat Building
Other Transportation
Equipment Manufacturing
Other Transportation
Equipment Manufacturing
Motorcycle, Bicycle, and Parts
Manufacturing
Military Armored Vehicle, Tank, and Tank
Component Manufacturing
All Other Transportation Equipment
Manufacturing
Furniture and Related
Product Manufacturing
Household and Institutional
Furniture and Kitchen
Cabinet Manufacturing
Wood Kitchen Cabinet and
Countertop Manufacturing
Wood Kitchen Cabinet and Countertop
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom wood
kitchen cabinets and counter tops)
Household and Institutional
Furniture Manufacturing
Upholstered Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom made
upholstered household furniture)
Nonupholstered Wood Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture
nonupholstered, household type, custom
wood furniture)
Metal Household Furniture Manufacturing
Household Furniture (except Wood and
Metal)
Manufacturing
337127
337129
3372
33721
337211
337212
337214
337215
3379
33791
337910
33792
337920
339
3391
33911
339111
339112
339113
339114
Institutional Furniture Manufacturing
Wood Television, Radio, and Sewing
Machine Cabinet Manufacturing
Office Furniture (including
Fixtures)Manufacturing
Office Furniture (including
Fixtures)Manufacturing
Wood Office Furniture Manufacturing
Custom Architectural Woodwork and
Millwork Manufacturing
Office Furniture (except Wood)
A /I -C 4-
Manufacturing
Showcase, Partition, Shelving, and Locker
Manufacturing
Other Furniture Related
Product Manufacturing
^5
Mattress Manufacturing
Mattress Manufacturing
Blind and Shade
Manufacturing
Blind and Shade Manufacturing
Miscellaneous Manufacturing
Medical Equipment and
Supplies Manufacturing
Medical Equipment and
Supplies Manufacturing
Laboratory Apparatus and Furniture Manuf.
Surgical and Medical Instrument
Manufacturing
Surgical Appliance and Supplies
Manufacturing (except facilities primarily
engaged in manufacturing orthopedic devices
to prescription in a retail environment )
Dental Equipment and Supplies
Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-17
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Table I. NAICS Codes
339115 Ophthalmic Goods Manufacturing (except
lens
grinding facilities that are primarily engaged
in the retail sale of eyeglasses and contact
lenses to prescription for individuals)
3399 Other Miscellaneous
Manufacturing
33991 Jewelry and Silverware
Manufacturing
339911 Jewelry (except Costume) Manufacturing
339912 Silverware and Hollowware Manufacturing
539913 Jewelers' Material and Lapidary Work
Manufacturing
339914 Costume Jewelry and Novelty Manufacturing
33992 Sporting and Athletic Goods
Manufacturing
339920 Sporting and Athletic Goods Manufacturing
33993 Doll, Toy, and Game
Manufacturing
339931 Doll and Stuffed Toy Manufacturing
339932 Game, Toy, and Children's Vehicle
Manufacturing
33994 Office Supplies (except Paper)
Manufacturing
3 3 9941 Pen and Mechanical Pencil Manufacturing
3 3 9942 Lead Pencil and Art Good Manufacturing
3 3 9943 Marking Device Manufacturing
3 3 9944 Carbon Paper and Inked Ribbon
Manufacturing
33995 Sign Manufacturing
339950 Sign Manufacturing
33999 All Other Miscellaneous
Manufacturing
539991 Gasket, Packing, and Sealing Device
Manufacturing
3 3 9992 Musical Instrument Manufacturing
339993 Fastener, Button, Needle, and Pin
Manufacturing
339994 Broom, Brush, and Mop Manufacturing
339995 Burial Casket Manufacturing
339999 All Other Miscellaneous Manufacturing
113310 Logging
111998 All Other Miscellaneous Crop Farming
(Limited to facilities primarily engaged in
reducing maple sap to maple syrup)
211112 Natural Gas Liquid Extraction (limited to
facilities that recover sulfur from natural gas)
212324 Kaolin and Ball Clay Mining (limited to
facilities operating without a mine or quarry
and that are primarily engaged in
beneficiating kaolin and clay)
212325 Clay and Ceramic and Refractory
Minerals Mining (limited to facilities
operating without a mine or quarry and that
are primarily engaged in beneficiating clay
and ceramic and refractory minerals)
212393 Other Chemical and Fertilizer Mineral
Mining (limited to facilities operating
without a mine or quarry that are primarily
engaged in beneficiating chemical or fertilizer
mineral raw materials)
212399 All Other Nonmetallic Mineral Mining
(limited to facilities operating without a mine
or quarry that are primarily engaged in
beneficiating nonmetallic minerals)
488390 Other Support Activities for Water
Transportation (limited to facilities that are
primarily engaged in providing routine repair
and maintenance of ships and boats from
floating drydocks)
511110 Newspaper Publishers
511120 Periodical Publishers
511130 Book Publishers
511140 Directory and Mailing List Publishers
(except Facilities that are primarily engaged
in furnishing services for direct mail
advertising including address list compilers,
address list publishers, address list publishers
and printing combined, address list
publishing, business directory publishers,
catalog of collections publishers, catalog of
collections publishers and printing combined,
mailing list compilers, directory compilers,
and mailing list compiling services)
511191 Greeting Card Publishers
511199 All Other Publishers
1-18
Toxics Release Inventory Reporting Form and Instructions
-------
Table I. NAICS Codes
512220 Integrated Record Production/Distribution
512230 Music Publishers (except facilities primarily
Engaged n Music copyright authorizing use,
Music copyright buying and licensing, and
Music publishers working on their own
account)
516110 Internet Publishing and Broadcasting and
web search portals (limited to facilities
primarily engaged in Internet newspaper
publishing, Internet periodical publishing,
internet book publishing, Miscellaneous
Internet publishing, Internet greeting card
publishers except web search portals
541710 Research and Development in the Physical,
Engineering, and Life Sciences except
Biotechnology (limited to facilities that are
primarily engaged in Guided missile and
space vehicle engine research and
development, and in Guided missile and
space vehicle parts (except engines) research
and development)
811490 Other Personal and Household Goods
Repair and Maintenance
1.2 NAICS codes that correspond
to SIC codes other than 20
through 39:
212 Mining (except Oil and Gas)
2121 Coal Mining
212111 Bituminous Coal and Lignite Surface Mining
212112 B ituminous Coal Underground Mining
212113 Anthracite Mining
2122 Metal Ore Mining
212221 Gold Ore Mining
212222 Silver Ore Mining
212231 Lead Ore and Zinc Ore Mining
212234 Copper Ore and Nickel Ore Mining
212299 All Other Metal Ore Mining
221
Utilities
22111 Electric Power Generation
(limited to facilities that combust
coal and/or oil for the purpose of
generating power for distribution
in commerce)
221111 Hydroelectric Power Generation
221112 Fossil Fuel Electric Power Generation
221113 Nuclear Electric Power Generation
221119 Other Electric Power Generation
221121 Electric Bulk Power Transmission and
Control
221122 Electric Power Distribution
221330 Steam and Air Conditioning Supply
Limited to facilities engaged in providing
combinations of electric, gas and other
services, not elsewhere classified (NEC)
(previously classified under SIC 4939,
Combination Utility Services Not Elsewhere
Classified.)
424690 Other Chemical and Allied Products
Merchant Wholesalers
424710 Petroleum Bulk Stations and Terminals
Toxics Release Inventory Reporting Form and Instructions
1-19
-------
Table I. NAICS Codes
425110 Business to Business Electronic Markets
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
425120 Wholesale Trade Agents and Brokers
(limited to facilities previously classified in
5169, Chemicals and Allied Products, NEC)
562112 Hazardous Waste Collection (limited to
facilities primarily engaged in solvent
recovery services on a contract or fee basis)
562211 Hazardous Waste Treatment and Disposal
(limited to facilities regulated under the
Resource Conservation and Recovery Act,
subtitle C, 42 U.S.C. 6921, et seq.)
562212 Solid Waste Landfill (limited to facilities
regulated under the Resource Conservation
and Recovery Act, subtitle C, 42 U.S.C.
6921, et seq.)
562213 Solid Waste Combustors and Incinerators
(Limited to facilities regulated under the
Resource Conservation and Recovery Act,
subtitle C, 42 U.S.C. 6921 et seq.)
562219 Other Nonhazardous Waste Treatment
and Disposal (Limited to facilities regulated
under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. 6921 et
seq)
562920 Materials Recovery Facilities (Limited to
facilities regulated under the Resource
Conservation and Recovery Act, subtitle C,
42 U.S.C. 6921 etseq.)
1-20
Toxics Release Inventory Reporting Form and Instructions
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Table II. EPCRA Section 313 Chemical List For Reporting Year 2009
(including Toxic Chemical Categories)
Individually listed EPCRA Section 313 chemicals with CAS numbers are arranged alphabetically starting on page II-3. Following the
alphabetical list, the EPCRA Section 313 chemicals are arranged in CAS number order. Covered chemical categories follow.
Certain EPCRA Section 313 chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that these EPCRA
Section 313 chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in a specific
form or when a certain activity is performed. The following chemicals are reportable only if they are manufactured, processed, or
otherwise used in the specific form(s) listed below:
Chemical
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonia (includes anhydrous ammonia and aqueous ammonia
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
Asbestos (friable)
Hydrochloric acid (acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle size)
Nitrate compounds (water dissociable; reportable only when in
aqueous solution)
Phosphorus (yellow or white)
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size)
Vanadium (except when contained in an alloy)
Zinc (fume or dust)
CAS Number
7429-90-5
1344-28-1
7664-41-7
1332-21-4
7647-01-0
NA
7723-14-0
7664-93-9
7440-62-2
7440-66-6
Qualifier
Only if it is a fume or dust form.
Only if it is a fibrous form.
Only 10% of aqueous forms. 100% of
anhydrous forms.
Only if it is a friable form.
Only if it is an aerosol form as
defined.
Only if in aqueous solution
Only if it is a yellow or white form.
Only if it is an aerosol form as
defined.
Except if it is contained in an alloy.
Only if it is in a fume or dust form.
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These chemicals
are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical/ Chemical Category
Dioxin and dioxin-like compounds (manufacturing; and the
processing or otherwise use of dioxin and dioxin-like compounds if
the dioxin and dioxin-like compounds are present as contaminants
in a chemical and if they were created during the manufacture of
that chemical.)
Isopropyl alcohol (only persons who manufacture by the strong
acid process are subject, no supplier notification)
Saccharin (only persons who manufacture are subject, no supplier
notification)
CAS
Number
NA
67-63-0
81-07-2
Qualifier
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in
a chemical but only if they were
created during the manufacture of that
chemical.
Only if it is being manufactured by the
strong acid process. Facilities that
process or otherwise use isopropyl
alcohol are not covered and should not
file a report.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals are
not required to report. Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA section
313 chemicals.
Toxics Release Inventory Reporting Form and Instructions
II-l
-------
Table II. EPCRA Section 313 Chemical List - RY2009
Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Right-to-Know Call Center
will provide up-to-date information on the status of these changes. See section B.3.c of the instructions for more information on the
de minimis values listed below. There are no de minimis levels for PBT chemicals since the de minimis exemption is not available
for these chemicals (an asterisk appears where a de minimis limit would otherwise appear in Table II). However, for purposes of the
supplier notification requirement only, such limits are provided in Appendix D.
Chemical Qualifiers
This table contains the list of individual EPCRA Section 313
chemicals and categories of chemicals subject to 2009 calendar year
reporting. Some of the EPCRA Section 313 chemicals listed have
parenthetic qualifiers listed next to them. An EPCRA Section 313
chemical that is listed without a qualifier is subject to reporting in all
forms in which it is manufactured, processed, and otherwise used.
Fume or dust Two of the metals on the list (aluminum and zinc)
contain the qualifier "fume or dust." Fume or dust refers to dry forms
of these metals but does not refer to "wet" forms such as solutions or
slurries. As explained in Section B. 3. a of these instructions, the term
manufacture includes the generation of an EPCRA Section 313
chemical as a byproduct or impurity. In such cases, a facility should
determine if, for example, it generated more than 25,000 pounds of
aluminum fume or dust in the reporting year as a result of its
activities. If so, the facility must report that it manufactures
"aluminum (fume or dust)." Similarly, there may be certain
technologies in which one of these metals is processed in the form of
a fume or dust to make other EPCRA Section 313 chemicals or other
products for distribution in commerce. In reporting releases, the
facility would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles generated by any
mechanical processing of materials including crushing, grinding,
rapid impact, handling, detonation, and decrepitation of organic and
inorganic materials such as rock, ore, and metal. Dusts do not tend to
flocculate, except under electrostatic forces.
EPA considers a fume to be an airborne dispersion consisting of small
solid particles created by condensation from a gaseous state, in
distinction to a gas or vapor. Fumes arise from the heating of solids
such as lead. The condensation is often accompanied by a chemical
reaction, such as oxidation. Fumes flocculate and sometimes
coalesce.
Manufacturing qualifiers. Two of the entries in the EPCRA Section
313 chemical list contain a qualifier relating to manufacture. For
isopropyl alcohol, the qualifier is "only persons who manufacture by
the strong acid process are subject, no supplier notification." For
saccharin, the qualifier is "only persons who manufacture are subject,
no supplier notification." For isopropyl alcohol, the qualifier means
that only facilities manufacturing isopropyl alcohol by the strong acid
process are required to report. In the case of saccharin, only
manufacturers of the EPCRA Section 313 chemical are subject to the
reporting requirements. A facility that only processes or otherwise
uses either of these EPCRA Section 313 chemicals is not required to
report for these EPCRA Section 313 chemicals. In both cases,
supplier notification does not apply because only manufacturers, not
users, of these two EPCRA Section 313 chemicals must report.
Ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts and other
sources; 10 percent of total aqueous ammonia is reportable
under this listing). The qualifier for ammonia means that
anhydrous forms of ammonia are 100% reportable and aqueous
forms are limited to 10% of total aqueous ammonia. Therefore
when determining threshold and releases and other waste
management quantities all anhydrous ammonia is included but
only 10% of total aqueous ammonia is included. Any
evaporation of ammonia from aqueous ammonia solutions is
considered anhydrous ammonia and should be included in
threshold determinations and release and other waste
management calculations.
Sulfuric acid and Hydrochloric acid (acid aerosols including
mists, vapors, gas, fog, and other airborne forms of any
particle size). The qualifier for sulfuric acid and hydrochloric
acid means that the only forms of these chemicals that are
reportable are airborne forms. Aqueous solutions are not covered
by this listing but any aerosols generated from aqueous solutions
are covered.
Nitrate compounds (water dissociable; reportable only when
in aqueous solution). The qualifier for the nitrate compounds
category limits the reporting to nitrate compounds that dissociate
in water, generating nitrate ion. For the purposes of threshold
determinations the entire weight of the nitrate compound must be
included in all calculations. For the purposes of reporting
releases and other waste management quantities only the weight
of the nitrate ion should be included in the calculations of these
quantities.
Phosphorus (yellow or white). The listing for phosphorus is
qualified by the term "yellow or white." This means that only
manufacturing, processing, or otherwise use of phosphorus in the
yellow or white chemical form triggers reporting. Conversely,
manufacturing, processing, or otherwise use of "black" or "red"
phosphorus does not trigger reporting. Supplier notification also
applies only to distribution of yellow or white phosphorus.
Asbestos (friable). The listing for asbestos is qualified by the
term "friable," referring to the physical characteristic of being
able to be crumbled, pulverized, or reducible to a powder with
hand pressure. Only manufacturing, processing, or otherwise use
of asbestos in the friable form triggers reporting. Supplier
notification applies only to distribution of mixtures or other trade
name products containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for aluminum
oxide is qualified by the term "fibrous forms." Fibrous refers to
a man-made form of aluminum oxide that is processed to produce
strands or filaments which can be cut to various lengths
depending on the application. Only manufacturing, processing,
or otherwise use of aluminum oxide in the fibrous form triggers
reporting. Supplier notification applies only to distribution of
Toxics Release Inventory Reporting Form and Instructions
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Table II. EPCRA Section 313 Chemical List - RY2009
mixtures or other trade name products containing fibrous forms of
aluminum oxide.
Notes for Sections A and B of following list of
TRI chemicals:
"Color Index" indicated by "C.I."
* There are no de minimis levels for PBT
chemicals, except for supplier notification
purposes (see Appendix D).
a.
Individually-Listed Toxic Chemicals Arranged
Alphabetically
CAS Number Chemical Name
Deminimis
% Limit
71751-41-2 Abamectin[AvermectinBl] 1.0
30560-19-1 Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
75-07-0 Acetaldehyde 0.1
60-35-5 Acetamide 0.1
75-05-8 Acetonitrile 1.0
98-86-2 Acetophenone 1.0
53-96-3 2-Acetylaminofluorene 0.1
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
2-nitrobenzoic acid, sodium salt]
107-02-8 Acrolein 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
15972-60-8 Alachlor 1.0
116-06-3 Aldicarb 1.0
309-00-2 Aldrin *
[l,4:5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
28057-48-9 d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of d-allethrone]
107-18-6 Allyl alcohol 1.0
107-11-9 Allylamine 1.0
107-05-1 Allyl chloride 1.0
7429-90-5 Aluminum (fume or dust) 1.0
20859-73-8 Aluminum phosphide 1.0
1344-28-1 Aluminum oxide (fibrous forms) 1.0
834-12-8 Ametryn 1.0
(N-Ethyl-N=-( 1 -methylethyl)-6-
(methylthio)-l,3,5,-triazine-2,4-diamine)
117-79-3 2-Aminoanthraquinone 0.1
60-09-3 4-Aminoazobenzene 0.1
92-67-1 4-Aminobiphenyl 0.1
82-28-0 l-Amino-2-methylanthraquinone 0.1
33089-61-1 Amitraz 1.0
61-82-5 Amitrole 0.1
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium
CAS Number Chemical Name
Deminimis
% Limit
salts and other sources; 10 percent of total
aqueous ammonia is reportable under this
listing)
101-05-3 Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
triazin-2-amine]
62-53-3 Aniline 1.0
90-04-0 o-Anisidine 0.1
104-94-9 p-Anisidine 1.0
134-29-2 o-Anisidine hydrochloride 0.1
120-12-7 Anthracene 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
1332-21-4 Asbestos (friable) 0.1
1912-24-9 Atrazine 1.0
(6-Chloro-N-ethyl-N=-(l-methylethyl)-
1,3,5-triazine-2,4-diamine)
7440-39-3 Barium 1.0
22781-23-3 Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
17804-35-2 Benomyl 1.0
98-87-3 Benzal chloride 1.0
55-21-0 Benzamide 1.0
71-43-2 Benzene 0.1
92-87-5 Benzidine 0.1
98-07-7 Benzoic trichloride 0.1
(Benzotrichloride)
191-24-2 Benzo(g,h,i)perylene *
98-88-4 Benzoyl chloride 1.0
94-36-0 Benzoyl peroxide 1.0
100-44-7 Benzyl chloride 1.0
7440-41-7 Beryllium 0.1
82657-04-3 Bifenthrin 1.0
92-52-4 Biphenyl 1.0
111-91-1 Bis(2-chloroethoxy) methane 1.0
111-44-4 Bis(2-chloroethyl) ether 1.0
542-88-1 Bis(chloromethyl) ether 0.1
108-60-1 Bis(2-chloro-l-methylethyl)ether 1.0
56-35-9 Bis(tributyltin) oxide 1.0
10294-34-5 Boron trichloride 1.0
7637-07-2 Boron trifluoride 1.0
314-40-9 Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
53404-19-6 Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione,5-bromo-6-
methyl-3-(l-methylpropyl), lithium salt]
7726-95-6 Bromine 1.0
35691-65-7 l-Bromo-l-(bromomethyl)- 1.0
1,3 -propanedicarbonitrile
353-59-3 Bromochlorodifluoromethane 1.0
(Halonl211)
75-25-2 Bromoform (Tribromomethane) 1.0
Toxics Release Inventory Reporting Form and Instructions
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
Deminimis
% Limit
74-83-9 Bromomethane 1.0
(Methyl bromide)
75-63-8 Bromotrifluoromethane 1.0
(Halon 1301)
1689-84-5 Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
1689-99-2 Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
357-57-3 Bracine 1.0
106-99-0 1,3-Butadiene 0.1
141-32-2 Butyl acrylate 1.0
71-36-3 n-Butyl alcohol 1.0
78-92-2 sec-Butyl alcohol 1.0
75-65-0 tert-Butyl alcohol 1.0
106-88-7 1,2-Butylene oxide 0.1
123-72-8 Butyraldehyde 1.0
7440-43-9 Cadmium 0.1
156-62-7 Calcium cyanamide 1.0
133-06-2 Captan 1.0
[lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
63-25-2 Carbaryl [1-Naphthalenol, 1.0
methylcarbamate]
1563-66-2 Carbofuran 1.0
75-15-0 Carbon disulfide 1.0
56-23-5 Carbon tetrachloride 0.1
463-58-1 Carbonyl sulfide 1.0
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-
phenyl-1,4-oxathiin-3 -carboxamide)
120-80-9 Catechol 0.1
2439-01-2 Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
133-90-4 Chloramben 1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
57-74-9 Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
115-28-6 Chlorendic acid 0.1
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-
2-y l)amino] carbony 1] amino] sulfonyl]
benzoate]
7782-50-5 Chlorine .0
10049-04-4 Chlorine dioxide .0
79-11-8 Chloroacetic acid .0
532-27-4 2-Chloroacetophenone .0
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza- .0
1-azoniaadamantane chloride
106-47-8 p-Chloroaniline 0.1
108-90-7 Chlorobenzene 1.0
510-15-6 Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.alpha.- (4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
75-68-3 l-Chloro-l,l-difluoroethane 1.0
(HCFC-142b)
75-45-6 Chlorodifluoromethane 1.0
CAS Number Chemical Name
Deminimis
% Limit
(HCFC-22)
75-00-3 Chloroethane (Ethyl chloride) 1.0
67-66-3 Chloroform 0.1
74-87-3 Chloromethane (Methyl chloride) 1.0
107-30-2 Chloromethyl methyl ether 0.1
563-47-3 3-Chloro-2-methyl-l-propene 0.1
104-12-1 p-Chlorophenyl isocyanate 1.0
76-06-2 Chloropicrin 1.0
126-99-8 Chloroprene 0.1
542-76-7 3-Chloropropionitrile 1.0
63938-10-3 Chlorotetrafluoroethane 1.0
354-25-6 1-Chloro-l, 1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
2837-89-0 2-Chloro-l,l,l,2- 1.0
tetrafluoroethane (HCFC-124)
1897-45-6 Chlorothalonil 0.1
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
95-69-2 p-Chloro-o-toluidine 0.1
75-88-7 2-Chloro-l,l,l- 1.0
trifluoroethane (HCFC-133a)
75-72-9 Chlorotrifluoromethane (CFC-13) 1.0
460-35-5 3-Chloro-l,l,l- 1.0
trifluoropropane (HCFC-253fb)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
64902-72-3 Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino] carbony 1]
benzenesulfonamide]
7440-47-3 Chromium 1.0
4680-78-8 C.I. Acid Green 3 1.0
6459-94-5 C.I. Acid Red 114 0.1
569-64-2 C.I. Basic Green 4 1.0
989-38-8 C.I. Basic Red 1 1.0
1937-37-7 C.I. Direct Black 38 0.1
2602-46-2 C.I. Direct Blue 6 0.1
28407-37-6 C.I. Direct Blue 218 1.0
16071-86-6 C.I. Direct Brown 95 0.1
2832-40-8 C.I. Disperse Yellow 3 1.0
3761-53-3 C.I. Food Red 5 0.1
81-88-9 C.I. Food Red 15 1.0
3118-97-6 C.I. Solvent Orange 7 1.0
97-56-3 C.I. Solvent Yellow 3 0.1
842-07-9 C.I. Solvent Yellow 14 1.0
492-80-8 C.I. Solvent Yellow 34 0.1
(Auramine)
128-66-5 C.I. Vat Yellow 4 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper 1.0
8001-58-9 Creosote 0.1
120-71-8 p-Cresidine 0.1
108-39-4 m-Cresol 1.0
95-48-7 o-Cresol 1.0
106-44-5 p-Cresol 1.0
1319-77-3 Cresol (mixed isomers) 1.0
4170-30-3 Crotonaldehyde 1.0
98-82-8 Cumene 1.0
Toxics Release Inventory Reporting Form and Instructions
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number
80-15-9
135-20-6
21725-46-2
1134-23-2
110-82-7
108-93-0
68359-37-5
68085-85-8
94-75-7
533-74-4
53404-60-7
94-82-6
1929-73-3
94-80-4
2971-38-2
1163-19-5
13684-56-5
1928-43-4
53404-37-8
2303-16-4
615-05-4
39156-41-7
101-80-4
95-80-7
25376-45-8
333-41-5
334-88-3
132-64-9
96-12-8
106-93-4
124-73-2
84-74-2
1918-00-9
99-30-9
95-50-1
541-73-1
Deminimis
Chemical Name % Limit
Cumene hydroperoxide 1.0
Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
Cyanazine .0
Cycloate .0
Cyclohexane .0
Cyclohexanol .0
Cyfluthrin .0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Cyhalothrin 1.0
[3 -(2-Chloro-3,3 ,3 -trifluoro- 1 -propenyl)-
2,2-dimethylcyclopropane-carboxylic acid
cyano(3-phenoxyphenyl)methyl ester]
2,4-D 0.1
[Acetic acid, (2,4-dichlorophenoxy)-]
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium]
2,4-DB 1.0
2,4-D butoxyethyl ester 0. 1
2,4-D butyl ester 0.1
2,4-D chlorocrotyl ester 0. 1
Decabromodipheny 1 oxide 1 . 0
De smedipham 1 . 0
2,4-D 2-ethylhexyl ester 0. 1
2,4-D 2-ethyl-4- 0.1
methylpentyl ester
Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2,4-Diaminoanisole 0.
2,4-Diaminoanisole sulfate 0.
4,4'-Diaminodiphenyl ether 0.
2,4-Diaminotoluene 0.
Diaminotoluene (mixed isomers) 0.
Diazinon 1.0
Diazomethane 1.0
Dibenzofuran 1.0
l,2-Dibromo-3- 0.1
chloropropane (DBCP)
1,2-Dibromoethane 0.1
(Ethylene dibromide)
Dibromotetrafluoroethane 1 . 0
(Halon 2402)
Dibutyl phthalate 1.0
Dicamba 1.0
(3 ,6-Dichloro-2-methoxybenzoic acid)
Dichloran 1.0
[2,6-Dichloro-4-nitroaniline]
1,2-Dichlorobenzene 1.0
1,3-Dichlorobenzene 1.0
Deminimis
CAS Number
106-46-7
25321-22-6
91-94-1
612-83-9
64969-34-2
75-27-4
764-41-0
110-57-6
1649-08-7
75-71-8
107-06-2
540-59-0
1717-00-6
75-43-4
75-09-2
127564-92-5
13474-88-9
111512-56-2
422-44-6
431-86-7
507-55-1
136013-79-1
128903-21-9
422-48-0
422-56-0
97-23-4
120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
76-14-2
34077-87-7
90454-18-5
812-04-4
354-23-4
306-83-2
62-73-7
Chemical Name %
1 ,4-Dichlorobenzene
Dichlorobenzene (mixed isomers)
3 ,3 '-Dichlorobenzidine
3 ,3 '-Dichlorobenzidine
dihydrochloride
3, 3 '-Dichlorobenzidine sulfate
Dichlorobromomethane
1 ,4-Dichloro-2-butene
trans- 1 ,4-Dichloro-2-butene
l,2-Dichloro-l,l-
difluoroethane (HCFC-132b)
Dichlorodifluoromethane (CFC-12)
1,2-Dichloroethane (Ethylene
dichloride)
1 ,2-Dichloroethylene
1 , 1 -Dichloro- 1 -fluoroethane
(HCFC-141b)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene
chloride)
Dichloropentafluoropropane
l,l-Dichloro-l,2,2,3,3-
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3-
pentafluoropropane (HCFC-225eb)
1,2-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225bb)
1,2-Dichloro-l, 1,3,3,3-
pentafluoropropane (HCFC-225da)
1,3 -Dichloro- 1,1, 2,2,3-
pentafluoropropane (HCFC-225cb)
1,3 -Dichloro- 1, 1,2,3,3-
pentafluoropropane (HCFC-225ea)
2,2-Dichloro-l, 1,1,3,3-
pentafluoropropane (HCFC-225aa)
2,3 -Dichloro- 1, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3, 3 -Dichloro- 1, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
2,4-Dichlorophenol
1 ,2-Dichloropropane
trans- 1 ,3 -Dichloropropene
2,3 -Dichloropropene
1 ,3 -Dichloropropylene
Dichlorotetrafluoroethane
(CFC-114)
Dichlorotrifluoroethane
Dichloro- 1 , 1 ,2-trifluoroethane
1,1 -Dichloro- 1,2,2-
trifluoroethane (HCFC-123b)
1,2-Dichloro-l, 1,2-
trifluoroethane (HCFC-123a)
2,2-Dichloro-l, 1,1-
trifluoroethane (HCFC-123)
Dichlorvos
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Limit
0.
0.
0.
0.
0.
0.
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
Toxics Release Inventory Reporting Form and Instructions
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
Deminimis
% Limit
51338-27-3 Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)phenoxy]
propanoic acid, methyl ester]
115-32-2 Dicofol 1.0
[Benzenemethanol, 4-chloro-
77-73-6 Dicyclopentadiene 1.0
1464-53-5 Diepoxybutane 0.1
111-42-2 Diethanolamine 1.0
38727-55-8 Diethatyl ethyl 1.0
117-81-7 Di(2-ethylhexyl) phthalate (DEHP) 0.1
64-67-5 Diethyl sulfate 0.1
35367-38-5 Diflubenzuron 1.0
101-90-6 Diglycidyl resorcinol ether 0.1
94-58-6 Dihydrosafrole 0.1
55290-64-7 Dimethipin 1.0
[2,3-Dihydro-5,6-dimethyl-l,4-dithiin
1,1,4,4-tetraoxide]
60-51-5 Dimethoate 1.0
119-90-4 3,3'-Dimethoxybenzidine 0.1
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine hydrochloride)
124-40-3 Dimethylamine 1.0
2300-66-5 Dimethylamine dicamba 1.0
60-11-7 4-Dimethylaminoazobenzene 0.1
121-69-7 N,N-Dimethylaniline 1.0
119-93-7 3,3'-Dimethylbenzidine(o-Tolidine) 0.1
612-82-8 3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine
dihydrochloride)
41766-75-0 3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidine dihydrofluoride)
79-44-7 Dimethylcarbamyl chloride 0.1
2524-03-0 Dimethyl 1.0
chlorothiophosphate
68-12-2 N,N-Dimethylformamide 1.0
57-14-7 U-Dimethylhydrazine 0.1
105-67-9 2,4-Dimethyrphenol 1.0
131-11-3 Dimethyl phthalate 1.0
77-78-1 Dimethyl sulfate 0.1
99-65-0 m-Dinitrobenzene 1.0
528-29-0 o-Dinitrobenzene 1.0
100-25-4 p-Dinitrobenzene 1.0
88-85-7 Dinitrobutyl phenol (Dinoseb) 1.0
534-52-1 4,6-Dinitro-o-cresol 1.0
51-28-5 2,4-Dinitrophenol 1.0
121-14-2 2,4-Dinitrotoluene 0.1
606-20-2 2,6-Dinitrotoluene 0.1
25321-14-6 Dinitrotoluene (mixed isomers) 1.0
39300-45-3 Dinocap 1.0
123-91-1 1,4-Dioxane 0.1
957-51-7 Diphenamid 1.0
122-39-4 Diphenylamine 1.0
122-66-7 1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1)heptane-2,3-
CAS Number Chemical Name
Deminimis
% Limit
dicarboxylic acid, dipotassium salt]
136-45-8 Dipropyl isocinchomeronate 1.0
138-93-2 Disodium 1.0
cyanodithioimidocarbonate
94-11-1 2,4-D isopropyl ester 0.1
541-53-7 2,4-Dithiobiuret 1.0
330-54-1 Diuron 1.0
2439-10-3 Dodine [Dodecylguanidine 1.0
monoacetate]
120-36-5 2,4-DP 0.1
1320-18-9 2,4-D propylene glycol 0.1
butyl ether ester
2702-72-9 2,4-D sodium salt 0.1
106-89-8 Epichlorohydrin 0.1
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
110-80-5 2-Ethoxyethanol 1.0
140-88-5 Ethyl acrylate 0.1
100-41-4 Ethylbenzene 0.1
541-41-3 Ethyl chloroformate 1.0
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
74-85-1 Ethylene 1.0
107-21-1 Ethylene glycol 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
75-21-8 Ethylene oxide 0.1
96-45-7 Ethylene thiourea 0.1
75-34-3 Ethylidene dichloride 1.0
52-85-7 Famphur 1.0
60168-88-9 Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrimidinemethanol]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
66441-23-4 Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic
acid, ethyl ester]
72490-01-8 Fenoxycarb 1.0
[[2-(4-Phenoxyphenoxy)ethyl]carbamic acid
ethyl ester]
39515-41-8 Fenpropathrin 1.0
[2,2,3,3 -Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
55-38-9 Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
51630-58-1 Fenvalerate 1.0
[4-Chloro-alpha-(l-methylethyl)
benzeneacetic acid cyano (3-
phenoxyphenyl) methyl ester]
14484-64-1 Ferbam 1.0
|Tris(dimethylcarbamodithioato- S,S')iron]
Toxics Release Inventory Reporting Form and Instructions
II-6
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number
69806-50-4
2164-17-2
7782-41-4
51-21-8
69409-94-5
133-07-3
72178-02-0
50-00-0
64-18-6
76-13-1
76-44-8
118-74-1
87-68-3
319-84-6
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
110-54-3
51235-04-2
67485-29-4
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
35554.44-0
55406-53-6
13463-40-6
78-84-2
465-73-6
25311-71-1
Deminimis
Chemical Name % Limit
Fluazif op butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
Fluometuron 1.0
[Urea, N,N-dimethyl-N=-[3-
(trifluoromethy l)pheny 1] -]
Fluorine 1.0
Fluorouracil (5 -Fluorouracil) 1 . 0
Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]-
DL-valine(+)-cyano(3 -
phenoxyphenyl)methyl ester]
Folpet 1.0
Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
N-methylsulfonyl-2-nitrobenzamide]
Formaldehyde 0.1
Formic acid 1.0
FreonllS 1.0
[Ethane, 1 , 1 ,2-trichloro- 1 ,2,2,-trifluoro-]
Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a, 4,7,7a-
tetrahydro-4,7-methano-lH-indene]
Hexachlorobenzene *
Hexachloro- 1,3 -butadiene 1.0
alpha-Hexachlorocyclohexane 0.1
Hexachlorocy clopentadiene 1 . 0
Hexachloroethane 0.1
Hexachloronaphthalene .0
Hexachlorophene .0
Hexamethylphosphoramide 0.1
n-Hexane .0
Hexazinone .0
Hydramethylnon .0
[Tetrahydro-5,5-dimethyl-2(lH)-
py rimidinone [3 - [4-(trifluoromethy l)pheny 1] -
l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
propeny lidene] hy drazone]
Hydrazine 0.1
Hydrazine sulfate 0.1
Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
Hydrogen cyanide 1 . 0
Hydrogen fluoride 1 . 0
Hydroquinone 1.0
Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl] - IH-imidazole]
3-Iodo-2-propynyl 1.0
butylcarbamate
Iron pentacarbony 1 1 . 0
Isobuty raldehy de 1 . 0
Isodrin *
Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]phosphinothioyl]oxy]
CAS Number
67-63-0
80-05-7
120-58-1
77501-63-4
7439-92-1
58-89-9
330-55-2
554-13-2
121-75-5
108-31-6
109-77-3
12427-38-2
7439-96-5
93-65-2
149-30-4
7439.97-6
150-50-5
126-98-7
137-42-8
67-56-1
20354-26-1
2032-65-7
94-74-6
3653-48-3
72-43-5
109-86-4
96-33-3
1634-04-4
79-22-1
101-14-4
101-61-1
74-95-3
101-77-9
Deminimis
Chemical Name % Limit
benzoic acid 1-methylethyl ester]
Isopropyl alcohol 1.0
(only persons who manufacture by the
strong acid process are subject, no supplier
notification)
4,4'-Isopropylidenediphenol 1.0
Isosafrole 1.0
Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,
6.beta.)-]
Linuron 1.0
Lithium carbonate 1.0
Malathion 1.0
Maleic anhydride 1.0
Malononitrile 1.0
Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
Manganese 1.0
Mecoprop 0.1
2-Mercaptobenzothiazole (MET) 1.0
Mercury *
Merphos 1.0
Methacrylonitrile 1.0
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Methanol 1.0
Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3 , 5 -dione]
Methiocarb 1.0
Methoxone 0.1
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt 0. 1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor *
[Benzene, 1, 1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
2-Methoxyethanol 1.0
Methyl acrylate 1.0
Methyl tert-butyl ether 1 .0
Methyl chlorocarbonate 1.0
4,4'-Methylenebis(2-chloroaniline) 0. 1
(MBOCA)
4,4'-Methylenebis(N,N-dimethyl) 0. 1
benzenamine
Methylene bromide 1.0
4,4'-Methylenedianiline 0.1
Toxics Release Inventory Reporting Form and Instructions
II-7
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
Deminimis
% Limit
60-34-4 Methyl hydrazine .0
74-88-4 Methyl iodide .0
108-10-1 Methyl isobutyl ketone .0
624-83-9 Methyl isocyanate .0
556-61-6 Methyl isothiocyanate .0
[Isothiocyanatomethane]
75-86-5 2-Methyllactonitrile .0
80-62-6 Methyl methacrylate .0
924-42-5 N-Methylolacrylamide .0
298-00-0 Methyl parathion .0
109-06-8 2-Methylpyridine .0
872-50-4 N-Methyl-2-pyrrolidone .0
9006-42-2 Metiram .0
21087-64-9 Metribuzin .0
7786-34-7 Mevinphos .0
90-94-8 Michler's ketone 0.1
2212-67-1 Molinate 1.0
(IH-Azepine-l-carbothioic acid, hexahydro-
, S-ethyl ester)
1313-27-5 Molybdenum trioxide 1.0
76-15-3 Monochloropentafluoroethane 1.0
(CFC-115)
150-68-5 Monuron 1.0
505-60-2 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]
88671-89-0 Myclobutanil 1.0
[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-lH-
1,2,4-triazole-1 -propanenitrile]
142-59-6 Nabam 1.0
300-76-5 Naled 1.0
91-20-3 Naphthalene 0.1
134-32-7 alpha-Naphthylamine 0.1
91-59-8 beta-Naphthylamine 0.1
7440-02-0 Nickel 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
7697-37-2 Nitric acid 1.0
139-13-9 Nitrilotriacetic acid 0.1
100-01-6 p-Nitroaniline 1.0
99-59-2 5-Nitro-o-anisidine 1.0
98-95-3 Nitrobenzene 0.1
92-93-3 4-Nitrobiphenyl 0.1
1836-75-5 Nitrofen 0.1
[Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-]
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
55-63-0 Nitroglycerin 1.0
88-75-5 2-Nitrophenol 1.0
100-02-7 4-Nitrophenol 1.0
79-46-9 2-Nitropropane 0.1
924-16-3 N-Nitrosodi-n-butylamine 0.1
55-18-5 N-Nitrosodiethylamine 0.1
62-75-9 N-Nitrosodimethylamine 0.1
86-30-6 N-Nitrosodiphenylamine 1.0
156-10-5 p-Nitrosodiphenylamine 1.0
621-64-7 N-Nitrosodi-n-propylamine 0.1
759-73-9 N-Nitroso-N-ethylurea 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
CAS Number Chemical Name
Deminimis
% Limit
1.0
*
1.0
1.0
1.0
1.0
4549-40-0 N-Nitrosomethylvinylamine 0.1
59-89-2 N-Nitrosomorpholine 0.1
16543-55-8 N-Nitrosonornicotine 0.1
100-75-4 N-Nitrosopiperidine 0.1
99-55-8 5-Nitro-o-toluidine 1.0
27314-13-2 Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl] -3 (2H)-
pyridazinone]
2234-13-1 Octachloronaphthalene
29082-74-4 Octachlorostyrene
19044-88-3 Oryzalin
[4-(Dipropylamino)-3,5-dinitrobenzene
sulfonamide]
20816-12-0 Osmium tetroxide
301-12-2 Oxydemeton methyl
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
19666-30-9 Oxydiazon
[3-[2,4-Dichloro-5-(l-
methylethoxy)phenyl]- 5-(l,l-
dimethylethyl)-l,3,4-oxadiazol-2(3H)-one]
42874-03-3 Oxyfluorfen 1.0
10028-15-6 Ozone 1.0
123-63-7 Paraldehyde 1.0
1910-42-5 Paraquat dichloride 1.0
56-38-2 Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl)ester]
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
40487-42-1 Pendimethalin *
[N-(l-Ethylpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
608-93-5 Pentachlorobenzene *
76-01-7 Pentachloroethane 1.0
87-86-5 Pentachlorophenol (PCP) 0.1
57-33-0 Pentobarbital sodium 1.0
79-21-0 Peracetic acid 1.0
594-42-3 Perchloromethyl mercaptan 1.0
52645-53-1 Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, (3-
phenoxyphenyl) methyl ester]
85-01-8 Phenanthrene 1.0
108-95-2 Phenol 1.0
26002-80-2 Phenothrin 1.0
[2,2-Dimethyl-3 -(2-methyl-l -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
95-54-5 1,2-Phenylenediamine 1.0
108-45-2 1,3-Phenylenediamine 1.0
106-50-3 p-Phenylenediamine 1.0
615-28-1 1,2-Phenylenediamine dihydro- 1.0
chloride
624-18-0 1,4-Phenylenediamine dihydro- 1.0
chloride
90-43-7 2-Phenylphenol 1.0
Toxics Release Inventory Reporting Form and Instructions
II-8
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
Deminimis
% Limit
57-41-0 Phenytoin 0.1
75-44-5 Phosgene 1.0
7803-51-2 Phosphine 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
85-44-9 Phthalic anhydride 1.0
1918-02-1 Picloram 1.0
88-89-1 Picric acid 1.0
51-03-6 Piperonyl butoxide 1.0
29232-93-7 Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-
dimethylphosphorothioate]
1336-36-3 Polychlorinated biphenyls *
(PCBs)
7758-01-2 Potassium bromate 0.1
128-03-0 Potassium dimethyldithio- 1.0
carbamate
137-41-7 Potassium N-methyldithio- 1.0
carbamate
41198-08-7 Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
7287-19-6 Prometryn 1.0
[N,N' -Bis( 1 -methylethyl)-6-methylthio-
l,3,5-triazine-2,4-diamine]
23950-58-5 Pronamide 1.0
1918-16-7 Propachlor 1.0
[2-Chloro-N-( 1 -methylethyl)-N-
phenylacetamide]
1120-71-4 Propane sultone 0.1
709-98-8 Propanil 1.0
[N-(3,4-Dichlorophenyl)propanamide]
2312-35-8 Propargite 1.0
107-19-7 Propargyl alcohol 1.0
31218-83-4 Propetamphos 1.0
[3-[(Ethylamino)methoxyphosphinothioyl]
oxy]-2-butenoic acid, 1-methylethyl ester]
60207-90-1 Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
dioxolan-2-yl]-methyl-1H-1,2,4,-triazole]
57-57-8 beta-Propiolactone 0.1
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene) 1.0
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
110-86-1 Pyridine 1.0
91-22-5 Quinoline 1.0
106-51-4 Quinone 1.0
82-68-8 Quintozene 1.0
(Pentachloronitrobenzene)
76578-14-8 Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid
ethyl ester]
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
CAS Number Chemical Name
Deminimis
% Limit
dimethyl-3-(2-methyl-l-propenyl)
cyclopropanecarboxylate]
81-07-2 Saccharin (only persons who 1.0
manufacture are subject, no supplier
notification)
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
74051-80-2 Sethoxydim 1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-
cyclohexen-1-one]
7440-22-4 Silver 1.0
122-34-9 Simazine 1.0
26628-22-8 Sodium azide 1.0
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
128-04-1 Sodium dimethyldithiocarbamate 1.0
62-74-8 Sodium fluoroacetate 1.0
7632-00-0 Sodium nitrite 1.0
131 -52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
35400-43-2 Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl]
phosphorodithioic acid S-propylester]
34014-18-1 Tebuthiuron 1.0
[N-[5-( 1,1 -Dimethylethyl)-1,3,4-thiadiazol-
2-yl] -N,N' -dimethylurea]
3383-96-8 Temephos 1.0
5902-51-2 Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
79-94-7 Tetrabromobisphenol A *
630-20-6 1,1,1,2-Tetrachloroethane 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
127-18-4 Tetrachloroethylene 0.1
(Perchloroethylene)
354-11-0 l,l,l,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane 1.0
(HCFC-121)
961-11-5 Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl) ethenyl dimethyl ester]
64-75-5 Tetracycline hydrochloride 1.0
7696-12-0 Tetramethrin 1.0
[2,2-Dimethyl-3-(2-methyl-l-propenyl)
cyclopropanecarboxylic acid (1,3,4,5,6,7-
hexahydro-1,3 -dioxo-2H-isoindol-2-
yl)methyl ester]
Toxics Release Inventory Reporting Form and Instructions
II-9
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
Deminimis
% Limit
1.0
7440-28-0 Thallium 1.0
148-79-8 Thiabendazole 1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
62-55-5 Thioacetamide 0.1
28249-77-6 Thiobencarb 1.0
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
139-65-1 4,4'-Thiodianiline 0.1
59669-26-0 Thiodicaib 1.0
23564-06-9 Thiophanate ethyl 1.0
[[1,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethylester]
23564-05-8 Thiophanate methyl 1.0
79-19-6 Thiosemicarbazide 1.0
62-56-6 Thiourea 0.1
137-26-8 Thiram 1.0
1314-20-1 Thorium dioxide 1.0
7550-45-0 Titanium tetrachloride 1.0
108-88-3 Toluene 1.0
584-84-9 Toluene-2,4-diisocyanate 0
91-08-7 Toluene-2,6-diisocyanate 0
26471-62-5 Toluene diisocyanate (mixed 0
isomers)
95-53-4 o-Toluidine
636-21-5 o-Toluidine hydrochloride
8001-35-2 Toxaphene
43121-43-3 Triadimefon
[1-(4-Chlorophenoxy)-3,3-di-methyl-1-(1H-
1,2,4- triazol-l-yl)-2-butanone]
2303-17-5 Triallate 1.0
68-76-8 Triaziquone 1.0
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
yl)-methylamino]-carbonyl]amino]sulfonyl]
benzoic acid methyl ester)
1983-10-4 Tributyltin fluoride 1.0
2155-70-6 Tributyltin methacrylate 1.0
78-48-8 S,S,S-Tributyltrithio- 1.0
phosphate (DBF)
52-68-6 Trichlorfon 1.0
[Phosphoric acid,(2,2,2-trichloro-l-hydroxy-
ethyl)-, dimethyl ester]
76-02-8 Trichloroacetyl chloride 1.0
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane (Methyl 1.0
chloroform)
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
75-69-4 Trichlorofluoromethane(CFC-ll) 1.0
95-95-4 2,4,5-Trichlorophenol 1.0
88-06-2 2,4,6-Trichlorophenol 0.1
96-18-4 1,2,3-Trichloropropane 0.1
57213-69-1 Triclopyr triethylammonium salt 1.0
121-44-8 Triethylamine 1.0
1582-09-8 Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-dipropyl-
4-(trifluoromethyl)-1
CAS Number
26644-46-2
95-63-6
2655-15-4
639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8
108-05-4
593-60-2
75-01-4
75-35-4
108-38-3
95-47-6
106-42-3
1330-20-7
87-62-7
7440-66-6
12122-67-7
Deminimis
Chemical Name % Limit
Triforine
[N,N'-[l,4-Piperazinediylbis-(2,2,2-
trichloroethylidene)]bisformamide]
1 ,2,4-Trimethylbenzene
2,3,5-Trimethylphenyl
methylcarbamate
Triphenyltin chloride
Triphenyltin hydroxide
Tris(2,3 -dibromopropyl)
phosphate
Trypan blue
Urethane (Ethyl carbamate)
Vanadium (except when contained
in an alloy)
Vinclozolin
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-
methyl-2,4-oxazolidinedione]
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride
m-Xylene
o-Xylene
p-Xylene
Xylene (mixed isomers)
2,6-Xylidine
Zinc (fume or dust)
Zineb
[Carbamodithioic acid, 1,2-ethanediyibis-
zinc complex]
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
Toxics Release Inventory Reporting Form and Instructions
11-10
-------
Table II. EPCRA Section 313 Chemical List - RY2009
b.
Individually Listed Toxic Chemicals Arranged
by CAS Number
De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
50-00-0
51-03-6
51-21-8
51-28-5
51-75-2
51-79-6
52-68-6
52-85-7
53-96-3
55-18-5
55-21-0
55-38-9
55-63-0
56-23-5
56-35-9
56-38-2
57-14-7
57-33-0
57-41-0
57-57-8
57-74-9
58-89-9
59-89-2
60-09-3
60-11-7
60-34-4
60-35-5
60-51-5
61-82-5
62-53-3
62-55-5
62-56-6
62-73-7
62-74-8
62-75-9
63-25-2
Formaldehyde 0.1
Piperonyl butoxide 1.0
Fluorouracil (5-Fluorouracil) 1.0
2,4-Dinitrophenol 1.0
Nitrogen mustard 0 . 1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Urethane (Ethyl carbamate) 0.1
Trichlorfon 1.0
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxy ethyl)-, dimethyl ester]
Famphur 1.0
2-Acetylaminofluorene 0.1
N-Nitrosodiethylamine 0.1
Benzamide 1.0
Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
Nitroglycerin 1.0
Carbon tetrachloride 0 . 1
Bis(tributyltin) oxide 1.0
Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
1,1-Dimethylhydrazine 0.1
Pentobarbital sodium 1.0
Phenytoin 0.1
beta-Propiolactone 0.1
Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha,
5.alpha.,6.beta.)-]
N-Nitrosomorpholine 0.1
4-Aminoazobenzene 0.1
4-Dimethylaminoazobenzene 0.1
Methyl hydrazine 1.0
Acetamide 0.1
Dimethoate 1.0
Amitrole 0.1
Aniline 1.0
Thioacetamide 0.1
Thiourea 0.1
Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Sodium fluoroacetate 1.0
N-Nitrosodimethylamine 0.1
Carbaryl 1.0
De minimis
CAS Number
Chemical Name % Limit
Arranged by CAS Number
64-18-6
64-67-5
64-75-5
67-56-1
67-63-0
[1-Naphthalenol, methylcarbamate]
Formic acid
Diethyl sulfate
Tetracycline hydrochloride
Methanol
Isopropyl alcohol
(only persons who manufacture by the
1.0
0.1
1.0
1.0
1.0
strong acid process are subject, no supplier
67-66-3
67-72-1
68-12-2
68-76-8
70-30-4
71-36-3
71-43-2
71-55-6
72-43-5
72-57-1
74-83-9
74-85-1
74-87-3
74-88-4
74-90-8
74-95-3
75-00-3
75-01-4
75-05-8
75-07-0
75-09-2
75-15-0
75-21-8
75-25-2
75-27-4
75-34-3
75-35-4
75-43-4
75-44-5
75-45-6
75-55-8
75-56-9
75-63-8
75-65-0
75-68-3
75-69-4
75-71-8
75-72-9
notification)
Chloroform
Hexachloroethane
N,N-Dimethylformamide
Triaziquone
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-
tris(l-aziridinyl)-]
Hexachlorophene
n-Butyl alcohol
Benzene
1,1,1 -Trichloroethane (Methyl
chloroform)
Methoxychlor
[Benzene, 1, 1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
Trypan blue
Bromomethane (Methyl bromide)
Ethylene
Chloromethane (Methyl chloride)
Methyl iodide
Hydrogen cyanide
Methylene bromide
Chloroethane (Ethyl chloride)
Vinyl chloride
Acetonitrile
Acetaldehyde
Dichloromethane (Methylene
chloride)
Carbon disulfide
Ethylene oxide
Bromoform (Tribromomethane)
Dichlorobromomethane
Ethylidene dichloride
Vinylidene chloride
Dichlorofluoromethane
(HCFC-21)
Phosgene
Chlorodifluoromethane
(HCFC-22)
Propyleneimine
Propylene oxide
Bromotrifluoromethane
(Halon 1301)
tert-Butyl alcohol
1 -Chloro- 1 , 1 -difluoroethane
(HCFC-142b)
Trichlorofluoromethane (CFC-11)
Dichlorodifluoromethane
(CFC-12)
Chlorotrifluoromethane (CFC-13)
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
*
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
Toxics Release Inventory Reporting Form and Instructions
11-11
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
75-86-5 2-Methyllactonitrile
75-88-7 2-Chloro-l,l,l-trifluoroethane
(HCFC-133a)
76-01-7 Pentachloroethane
76-02-8 Trichloroacetyl chloride
76-06-2 Chloropicrin
76-13-1 FreonllS
[Ethane, l,l,2-trichloro-l,2,2,-trifluoro-]
76-14-2 Dichlorotetrafluoroethane 1.0
(CFC-114)
76-15-3 Monochloropentafluoroethane 1.0
(CFC-115)
76-44-8 Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-
tetrahydro-4,7-methano-lH-indene]
76-87-9 Triphenyltin hydroxide 1.0
77-47-4 Hexachlorocyclopentadiene 1.0
77-73-6 Dicyclopentadiene 1.0
77-78-1 Dimethyl sulfate 0.1
78-48-8 S,S,S-Tributyltrithiophosphate 1.0
(DBF)
78-84-2 Isobutyraldehyde 1.0
78-87-5 1,2-Dichloropropane 1.0
78-88-6 2,3-Dichloropropene 1.0
78-92-2 sec-Butyl alcohol 1.0
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 0.1
79-06-1 Acrylamide 0.1
79-10-7 Aery lie acid 1.0
79-11-8 Chloroacetic acid 1.0
79-19-6 Thiosemicarbazide 1.0
79-21-0 Peracetic acid 1.0
79-22-1 Methyl chlorocarbonate 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
79-44-7 Dimethylcarbamyl chloride 0.1
79-46-9 2-Nitropropane 0.1
79-94-7 Tetrabromobisphenol A *
80-05-7 4,4'-Isopropylidenediphenol 1.0
80-15-9 Cumene hydroperoxide 1.0
80-62-6 Methyl methacry late 1.0
81-07-2 Saccharin (only persons who 1.0
manufacture are subject, no supplier
notification)
81-88-9 C.I. Food Red 15 1.0
82-28-0 l-Amino-2-methylanthraquinone 0.1
82-68-8 Quintozene 1.0
[Pentachloronitrobenzene]
84-74-2 Dibutyl phthalate 1.0
85-01-8 Phenanthrene 1.0
85-44-9 Phthalic anhydride 1.0
86-30-6 N-Nitrosodiphenylamine 1.0
87-62-7 2,6-Xylidine 0.1
87-68-3 Hexachloro-1,3-butadiene 1.0
87-86-5 Pentachlorophenol (PCP) 0.1
88-06-2 2,4,6-Trichlorophenol 0.1
88-75-5 2-Nitrophenol 1.0
88-85-7 Dinitrobutyl phenol (Dinoseb) 1.0
88-89-1 Picric acid 1.0
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
90-04-0 o-Anisidine 0.1
90-43-7 2-Phenylphenol 1.0
90-94-8 Michler's ketone 0.
91-08-7 Toluene-2,6-diisocyanate 0.
91-20-3 Naphthalene 0.
91-22-5 Quinoline 1.0
91-59-8 beta-Naphthylamine 0.
91-94-1 3,3'-Dichlorobenzidine 0.
92-52-4 Biphenyl 1.0
92-67-1 4-Aminobiphenyl 0.
92-87-5 Benzidine 0.
92-93-3 4-Nitrobiphenyl 0.
93-65-2 Mecoprop 0.
94-11-1 2,4-D isopropyl ester 0.
94-36-0 Benzoyl peroxide 1.0
94-58-6 Dihydrosafrole 0.
94-59-7 Safrole 0.
94-74-6 Methoxone 0.
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
94-75-7 2,4-D [Acetic acid, (2,4- 0.1
dichlorophenoxy)-]
94-80-4 2,4-D butyl ester 0.1
94-82-6 2,4-DB 1.0
95.47-6 o-Xylene 1.0
95-48-7 o-Cresol 1.0
95-50-1 1,2-Dichlorobenzene 1.0
95-53-4 o-Toluidine 0.1
95-54-5 1,2-Phenylenediamine 1.0
95-63-6 1,2,4-Trimethylbenzene 1.0
95-69-2 p-Chloro-o-toluidine 0.1
95-80-7 2,4-Diaminotoluene 0.1
95-95-4 2,4,5-Trichlorophenol 1.0
96-09-3 Styrene oxide 0.1
96-12-8 l,2-Dibromo-3-chloropropane 0.1
(DBCP)
96-18-4 1,2,3-Trichloropropane 0.1
96-33-3 Methyl aery late 1.0
96-45-7 Ethylene thiourea 0.1
97-23-4 Dichlorophene 1.0
[2,2'-Methylenebis(4-chlorophenol)]
97-56-3 C.I. Solvent Yellow 3 0.1
98-07-7 Benzoic trichloride 0.1
(Benzotrichloride)
98-82-8 Cumene 1.0
98-86-2 Acetophenone 1.0
98-87-3 Benzal chloride 1.0
98-88-4 Benzoyl chloride 1.0
98-95-3 Nitrobenzene 0.1
99-30-9 Dichloran [2,6-Dichloro-4- 1.0
nitroaniline]
99-55-8 5-Nitro-o-toluidine 1.0
99-59-2 5-Nitro-o-anisidine 1.0
99-65-0 m-Dinitrobenzene 1.0
100-01-6 p-Nitroaniline 1.0
100-02-7 4-Nitrophenol 1.0
100-25-4 p-Dinitrobenzene 1.0
100-41-4 Ethylbenzene 0.1
Toxics Release Inventory Reporting Form and Instructions
11-12
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
100-42-5 Styrene 0.1
100-44-7 Benzyl chloride 1.0
100-75-4 N-Nitrosopiperidine 0.1
101-05-3 Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
triazin-2-amine]
101-14-4 4,4'-Methylenebis(2-chloroanirine) 0.1
(MBOCA)
101-61-1 4,4'-Methylenebis(N,N- 0.1
dimethyl)benzenamine
101-77-9 4,4'-Methylenedianiline 0.1
101-80-4 4,4'-Diaminodiphenyl ether 0.1
101-90-6 Diglycidyl resorcinol ether 0.1
104-12-1 p-Chlorophenyl isocyanate 1.0
104-94-9 p-Anisidine 1.0
105-67-9 2,4-Dimethylphenol 1.0
106-42-3 p-Xylene 1.0
106-44-5 p-Cresol 1.0
106-46-7 1,4-Dichlorobenzene 0.1
106-47-8 p-Chloroaniline 0.1
106-50-3 p-Phenylenediamine 1.0
106-51-4 Quinone 1.0
106-88-7 1,2-Butylene oxide 0.1
106-89-8 Epichlorohydrin 0.1
106-93-4 1,2-Dibromoethane 0.1
(Ethylene dibromide)
106-99-0 1,3-Butadiene 0.1
107-02-8 Acrolein 1.0
107-05-1 Allyl chloride 1.0
107-06-2 1,2-Dichloroethane (Ethylene 0.1
dichloride)
107-11-9 Allylamine 1.0
107-13-1 Acrylonitrile 0.1
107-18-6 Allyl alcohol 1.0
107-19-7 Propargyl alcohol 1.0
107-21-1 Ethylene glycol 1.0
107-30-2 Chloromethyl methyl ether 0.1
108-05-4 Vinyl acetate 0.1
108-10-1 Methyl isobutyl ketone .0
108-31-6 Maleic anhydride
108-38-3 m-Xylene
108-39-4 m-Cresol
108-45-2 1,3-Phenylenediamine
108-60-1 Bis(2-chloro-l-methylethyl) ether
108-88-3 Toluene
108-90-7 Chlorobenzene
108-93-0 Cyclohexanol
108-95-2 Phenol
109-06-8 2-Methylpyridine
109-77-3 Malononitrile
109-86-4 2-Methoxyethanol
110-54-3 n-Hexane
110-57-6 trans-l,4-Dichloro-2-butene
110-80-5 2-Ethoxyethanol
110-82-7 Cyclohexane
110-86-1 Pyridine
111 -42-2 Diethanolamine
111-44-4 Bis(2-chloroethyl) ether
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
111-91-1 Bis(2-chloroethoxy) methane 1.0
114-26-1 Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene) 1.0
115-28-6 Chlorendic acid 0.1
115-32-2 Dicofol 1.0
[Benzenemethanol, 4-chloro-.alpha.-4-
(chlorophenyl)-.alpha.-(trichloromethyl)-]
116-06-3 Aldicarb 1.0
117-79-3 2-Aminoanthraquinone 0.1
117-81-7 Di(2-ethylhexyl) phthalate 0.1
118-74-1 Hexachlorobenzene *
119-90-4 3,3'-Dimethoxybenzidine 0.1
119-93-7 3,3'-Dimethylbenzidine 0.1
(o-Tolidine)
120-12-7 Anthracene 1.0
120-36-5 2,4-DP 0.1
120-58-1 Isosafrole 1.0
120-71-8 p-Cresidine 0.1
120-80-9 Catechol 0.1
120-82-1 1,2,4-Trichlorobenzene 1.0
120-83-2 2,4-Dichlorophenol 1.0
121-14-2 2,4-Dinitrotoluene 0.1
121-44-8 Triethylamine 1.0
121-69-7 N,N-Dimethylaniline 1.0
121-75-5 Malathion 1.0
122-34-9 Simazine 1.0
122-39-4 Diphenylamine 1.0
122-66-7 1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
123-31-9 Hydroquinone 1.0
123-38-6 Propionaldehyde 1.0
123-63-7 Paraldehyde 1.0
123-72-8 Butyraldehyde 1.0
123-91-1 1,4-Dioxane 0.1
124-40-3 Dimethylamine 1.0
124-73-2 Dibromotetrafluoroethane 1.0
(Halon2402)
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
126-98-7 Methacrylonitrile 1.0
126-99-8 Chloroprene 0.1
127-18-4 Tetrachloroethylene 0.1
(Perchloroethylene)
128-03-0 Potassium 1.0
dimethyldithiocarbamate
128-04-1 Sodium dimethyldithiocarbamate 1.0
128-66-5 C.I. Vat Yellow 4 1.0
131-11-3 Dimethyl phthalate 1.0
131-52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
132-64-9 Dibenzofuran 1.0
133-06-2 Captan 1.0
[IH-Isoindole-1,3(2H)-dione, 3a,4,7,7a-
tetrahydro-2-[(trichloromethyl)thio]-]
133-07-3 Folpet 1.0
133-90-4 Chloramben 1.0
Toxics Release Inventory Reporting Form and Instructions
11-13
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number
De minimis
Chemical Name % Limit
Arranged by CAS Number
134-29-2
134-32-7
135-20-6
136-45-8
137-26-8
137-41-7
137-42-8
138-93-2
139-13-9
139-65-1
140-88-5
141-32-2
142-59-6
148-79-8
149-30-4
150-50-5
150-68-5
151-56-4
156-10-5
156-62-7
191-24-2
298-00-0
300-76-5
301-12-2
302-01-2
306-83-2
309-00-2
314-40-9
319-84-6
330-54-1
330-55-2
333-41-5
334-88-3
353-59-3
354-11-0
354-14-3
354-23-4
[Benzole acid, 3-amino-2,5-dichloro-]
o-Anisidine hydrochloride 0.1
alpha-Naphthylamine 0.1
Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate 1.0
Thiram 1.0
Potassium N-methyldithio- 1.0
carbamate
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Disodium cyanodithioimido- 1.0
carbonate
Nitrilotriacetic acid 0.1
4,4'-Thiodianiline 0.1
Ethyl aery late 0.1
Butyl aery late 1.0
Nabam 1.0
Thiabendazole 1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
2-Mercaptobenzothiazole 1.0
(MET)
Merphos 1.0
Monuron 1.0
Ethyleneimine (Aziridine) 0.1
p-Nitrosodiphenylamine 1.0
Calcium cyanamide 1.0
Benzo(g,h,i)perylene *
Methyl parathion 1.0
Naled 1.0
Oxydemeton methyl 1.0
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Hydrazine 0.1
2,2-Dichloro- 1 ,1,1 -trifluoroethane 1 .0
(HCFC-123)
Aldrin *
[ 1 ,4 : 5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
alpha-Hexachlorocyclohexane 0.1
Diuron .0
Linuron .0
Diazinon .0
Diazomethane .0
Bromochlorodifluoromethane .0
(Halonl211)
1,1, 1 ,2-Tetrachloro-2-fluoroethane 1 .0
(HCFC-121a)
1 , 1 ,2,2-Tetrachloro- 1 -fluoroethane 1 .0
(HCFC-121)
l,2-Dichloro-l,l,2- 1.0
trifluoroethane (HCFC-123a)
De minimis
CAS Number
Chemical Name %
Limit
Arranged by CAS Number
354-25-6
357-57-3
422-44-6
422-48-0
422-56-0
431-86-7
460-35-5
463-58-1
465-73-6
492-80-8
505-60-2
507-55-1
510-15-6
l-Chloro-1,1,2,2-
tetrafluoroethane (HCFC-124a)
Brucine
1,2-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225bb)
2,3-Dichloro-l, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
1,2-Dichloro-l, 1,3,3,3-
pentafluoropropane (HCFC-225da)
3 -Chloro- 1 ,1,1 -trifluoropropane
(HCFC-253fb)
Carbonyl sulfide
Isodrin
C.I. Solvent Yellow 34
(Auramine)
Mustard gas
[Ethane, l,l'-thiobis[2-chloro-]
1,3-Dichloro-l, 1,2,2,3-
pentafluoropropane (HCFC-225cb)
Chlorobenzilate
[Benzeneacetic acid, 4-chloro-.alpha
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
*
0.1
0.1
1.0
1.0
-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl
528-29-0
532-27-4
533-74-4
534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-61-6
563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608-93-5
612-82-8
612-83-9
615-05-4
615-28-1
621-64-7
624-18-0
ester]
o-Dinitrobenzene
2-Chloroacetophenone
Dazomet
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
4,6-Dinitro-o-cresol
1 ,2-Dichloroethylene
Ethyl chloroformate
2,4-Dithiobiuret
1 , 3 -Dichlorobenzene
1 , 3 -Dichloropropy lene
3 -Chloropropionitrile
Bis(chloromethyl) ether
Lithium carbonate
Methyl isothiocyanate
[Isothiocyanatomethane]
3 -Chloro-2 -methyl- 1 -propene
C.I. Basic Green 4
Toluene-2,4-diisocyanate
Vinyl bromide
Perchloromethyl mercaptan
2,6-Dinitrotoluene
Pentachlorobenzene
3 , 3 '-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3 , 3 '-Dichlorobenzidine
dihydrochloride
2,4-Diaminoanisole
1 ,2-Phenylenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1 ,4-Phenylenediamine
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
0.1
1.0
0.1
0.1
1.0
0.1
*
0.1
0.1
0.1
1.0
0.1
1.0
Toxics Release Inventory Reporting Form and Instructions
11-14
-------
Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
dihydrochloride
624-83-9 Methyl isocyanate 1.0
630-20-6 1,1,1,2-Tetrachloroethane 1.0
636-21-5 o-Toluidine hydrochloride 0.1
639-58-7 Triphenyltin chloride 1.0
680-31-9 Hexamethylphosphoramide 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
709-98-8 Propanil (N-(3,4-Dichlorophenyl) 1.0
propanamide)
759-73-9 N-Nitroso-N-ethylurea 0.1
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
764-41-0 l,4-Dichloro-2-butene 1.0
812-04-4 l,l-Dichloro-l,2,2-trifluoroethane 1.0
(HCFC-123b)
834-12-8 Ametryn 1.0
(N-Ethyl-N' -(1 -methylethyl)-6-
(methylthio)-l,3,5,-triazine-2,4-diamine)
842-07-9 C.I. Solvent Yellow 14 1.0
872-50-4 N-Methyl-2-pyrrolidone 1.0
924-16-3 N-Nitrosodi-n-butylamine 0.1
924-42-5 N-Methylolacrylamide 1.0
957-51-7 Diphenamid 1.0
961-11-5 Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-l-(2,4,5-
trichlorophenyl)ethenyldimethyl ester]
989-38-8 C.I. Basic Red 1 1.0
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-propyl
ester]
1120-71-4 Propane sultone 0.1
1134-23-2 Cycloate .0
1163-19-5 Decabromodiphenyl oxide .0
1313 -27-5 Molybdenum trioxide .0
1314-20-1 Thorium dioxide .0
1319-77-3 Cresol (mixed isomers) .0
1320-18-9 2,4-D propylene glycol butyl 0.1
ether ester
1330-20-7 Xylene (mixed isomers) 1.0
1332-21-4 Asbestos (friable) 0.1
1335-87-1 Hexachloronaphthalene 1.0
1336-36-3 Polychlorinated biphenyls (PCBs) *
1344-28-1 Aluminum oxide (fibrous forms) 1.0
1464-53-5 Diepoxybutane 0.1
1563-66-2 Carbofuran 1.0
1582-09-8 Trifluralin *
[Benezeneamine, 2,6-dinitro-N,N-
dipropyl-4-(trifluoromethyl)-]
1634-04-4 Methyl tert-butyl ether 1.0
1649-08-7 l,2-Dichloro-l,l-difluoroethane 1.0
(HCFC-132b)
1689-84-5 Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
1689-99-2 Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
1717-00-6 1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
1836-75-5 Nitrofen 0.1
[Benzene, 2,4-dichloro-l-(4-
nitrophenoxy)-]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
1897-45-6 Chlorothalonil 0.1
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
1910-42-5 Paraquat dichloride 1.0
1912-24-9 Atrazine 1.0
(6-Chloro-N-ethyl-N'-(l-methylethyl)-
l,3,5-triazine-2,4-diamine)
1918-00-9 Dicamba 1.0
(3,6-Dichloro-2-methoxybenzoic acid)
1918-02-1 Picloram 1.0
1918-16-7 Propachlor 1.0
[2-Chloro-N-(l-methylethyl)-N-
phenylacetamide]
1928-43-4 2,4-D 2-ethylhexyl ester 0.1
1929-73-3 2,4-D butoxyethyl ester 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)pyridine)
1937-37-7 C.I. Direct Black 38 0.1
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic acid,
sodium salt]
1983-10-4 Tributyltin fluoride 1.0
2032-65-7 Methiocarb 1.0
2155-70-6 Tributyltin methacrylate 1.0
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2. l)heptane-2,3-
dicarboxylic acid, dipotassium salt]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl] -]
2212-67-1 Molinate 1.0
(lH-Azepine-1-carbothioic acid,
hexahydro-S-ethyl ester)
2234-13-1 Octachloronaphthalene 1.0
2300-66-5 Dimethylamine dicamba 1.0
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2303-17-5 Triallate 1.0
2312-35-8 Propargite 1.0
2439-01-2 Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
one]
2439-10-3 Dodine 1.0
[Dodecylguanidine monoacetate]
2524-03-0 Dimethyl chlorothiophosphate 1.0
2602-46-2 C.I. Direct Blue 6 0.1
2655-15-4 2,3,5-Trimethylphenyl methyl 1.0
carbamate
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
2702-72-9 2,4-D sodium salt 0.1
Toxics Release Inventory Reporting Form and Instructions
11-15
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
2832-40-8 C.I. Disperse Yellow 3 1.0
2837-89-0 2-Chloro-l, 1,1,2- 1.0
tetrafluoroethane (HCFC-124)
2971-38-2 2,4-D Chlorocrotyl ester 0.1
3118-97-6 C.I. Solvent Orange 7 1.0
3383-96-8 Temephos 1.0
3653-48-3 Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
3761-53-3 C.I. Food Red 5 0.1
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza-l- 1.0
azoniaadamantane chloride
4170-30-3 Crotonaldehyde 1.0
4549-40-0 N-Nitrosomethylvinylamine 0.1
4680-78-8 C.I. Acid Green 3 1.0
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-phenyl-l,4-
oxathiin-3 -carboxamide)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
5902-51-2 Terbacil 1.0
[5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
2,4(lH,3H)-pyrimidinedione]
6459-94-5 C.I. Acid Red 114 0.1
7287-19-6 Prometryn 1.0
[N,N'-Bis(l-methylethyl)-6-methylthio-
1,3,5-triazine-2,4-diamine]
7429-90-5 Aluminum (fume or dust) 1.0
7439-92-1 Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level
is 0.1)
7439-96-5 Manganese 1.0
7439-97-6 Mercury *
7440-02-0 Nickel 0.1
7440-22-4 Silver 1.0
7440-28-0 Thallium 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
7440-39-3 Barium 1.0
7440-41-7 Beryllium 0.1
7440-43-9 Cadmium 0.1
7440-47-3 Chromium 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper
7440-62-2 Vanadium (except when contained
in an alloy)
7440-66-6 Zinc (fume or dust)
7550-45-0 Titanium tetrachloride
7632-00-0 Sodium nitrite
7637-07-2 Boron trifluoride
7647-01-0 Hydrochloric acid
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
(includes anhydrous ammonia and aqueous
ammonia from water dissociable
ammonium salts and other sources; 10
percent of total aqueous ammonia is
reportable under this listing)
7664-93-9 Sulfuric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any
particle size)
7696-12-0 Tetramethrin 1.0
[2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid
(l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
isoindol-2-yl)methyl ester]
7697-37-2 Nitric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
7726-95-6 Bromine 1.0
7758-01-2 Potassium bromate 0.1
7782-41-4 Fluorine 1.0
7782-49-2 Selenium 1.0
7782-50-5 Chlorine 1.0
7786-34-7 Mevinphos 1.0
7803-51-2 Phosphine 1.0
8001-35-2 Toxaphene *
8001-58-9 Creosote 0.1
9006-42-2 Metiram 1.0
10028-15-6 Ozone 1.0
10034-93-2 Hydrazine sulfate 0.1
10049-04-4 Chlorine dioxide 1.0
10061-02-6 trans-l,3-Dichloropropene 0.1
10294-34-5 Boron trichloride 1.0
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]methyl- 2,2-
dimethy 1-3 -(2-methyl-1 -propeny 1)
cy clopropanecarboxy late] ]
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
zinc complex]
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-phenylpropyl)
distannoxane)
13463-40-6 Iron pentacarbonyl 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
13684-56-5 Desmedipham 1.0
14484-64-1 Ferbam 1.0
[Tris(dimethy Icarbamodithioato -S, S' )iron]
15972-60-8 Alachlor 1.0
16071-86-6 C.I. Direct Brown 95 0.1
16543-55-8 N-Nitrosonornicotine 0.1
17804-35-2 Benomyl 1.0
19044-88-3 Oryzalin 1.0
Toxics Release Inventory Reporting Form and Instructions
11-16
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-methylethoxy)
phenyl]-5-(l,l-dimethylethyl)-l,3,4-
oxadiazol-2(3H)-one]
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5 -dione]
20816-12-0 Osmium tetroxide
20859-73-8 Aluminum phosphide
21087-64-9 Metribuzin
21725-46-2 Cyanazine
22781-23-3 Bendiocarb
[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
23564-05-8 Thiophanate methyl 1.0
23564-06-9 Thiophanate ethyl 1.0
[[l,2-Phenylenebis(iminocarbonothioyl)]
biscarbamic acid diethyl ester]
23950-58-5 Pronamide 1.0
25311-71-1 Isofenphos 1.0
[2-[[Ethoxyl[( 1 -methylethyl)-
amino]phosphinothioyl]oxy]benzoic acid
1-methylethyl ester]
25321-14-6 Dinitrotoluene (mixed isomers) 1.0
25321-22-6 Dichlorobenzene (mixed isomers) 0.1
25376-45-8 Diaminotoluene (mixed isomers) 0.1
26002-80-2 Phenothrin 1.0
[2,2-Dimethyl-3 -(2-methyl-l -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester]
26471-62-5 Toluene diisocyanate 0.1
(mixed isomers)
26628-22-8 Sodium azide 1.0
26644-46-2 Triforine 1.0
[N,N'-[l,4-Piperazinediylbis (2,2,2-
trichloroethylidene)]bisformamide]
27314-13-2 Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl] -3 (2H)-
pyridazinone]
28057-48-9 d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of d-
allethrone]
28249-77-6 Thiobencarb 1.0
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
28407-37-6 C.I. Direct Blue 218 1.0
29082-74-4 Octachlorostyrene *
29232-93-7 Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-
dimethylphosphorothioate]
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
30560-19-1 Acephate 1.0
(Acetylphosphoramidothioic acid O,S-
dimethyl ester)
31218-83-4 Propetamphos 1.0
[3-[(Ethylamino)
methoxyphosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
33089-61-1 Amitraz 1.0
34014-18-1 Tebuthiuron 1.0
[N-[5-(l,l-Dimethylethyl)-l,3,4-
thiadiazol-2-yl] -N,N' -dimethylurea]
34077-87-7 Dichlorotrifluoroethane 1.0
35367-38-5 Diflubenzuron 1.0
35400-43-2 Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl]-
phosphorodithioic acid S-propyl ester]
35554-44-0 Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl] -IH-imidazole]
35691-65-7 l-Bromo-l-(bromomethyl)-l,3- 1.0
propanedicarbonitrile
38727-55-8 Diethatyl ethyl 1.0
39156-41-7 2,4-Diaminoanisole sulfate 0.1
39300-45-3 Dinocap 1.0
39515-41-8 Fenpropathrin 1.0
[2,2,3,3 -Tetramethy Icy clopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
40487-42-1 Pendimethalin *
[N-( 1 -Ethylpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine]
41198-08-7 Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propyl phosphorothioate]
41766-75-0 3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-
Tolidinedihydrofluoride)
42874-03-3 Oxyfluorfen 1.0
43121-43-3 Triadimefon 1.0
[l-(4-Chlorophenoxy)-3,3-dimethyl-1-(1H-
1,2,4-triazol-1-yl)-2-butanone]
50471-44-8 Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-
methyl-2,4-oxazolidinedione]
51235-04-2 Hexazinone 1.0
51338-27-3 Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)-
phenoxy]propanoic acid, methyl ester]
51630-58-1 Fenvalerate 1.0
[4-Chloro-alpha-( 1 -methylethyl)-
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
52645-53-1 Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid,
(3-phenoxyphenyl)methyl ester]
53404-19-6 Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
Toxics Release Inventory Reporting Form and Instructions
11-17
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Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
methyl-3-(l-methylpropyl), lithium salt]
53404-37-8 2,4-D 2-ethyl-4-methylpentyl 0.1
ester
53404-60-7 Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-), sodium]
55290-64-7 Dimethipin 1.0
[2,3 -Dihydro-5,6-dimethyl-1,4-dithiin
1,1,4,4-tetraoxide]
55406-53-6 3-Iodo-2-propynylbutyl 1.0
carbamate
57213-69-1 Triclopyr triethylammonium salt 1.0
59669-26-0 Thiodicarb 1.0
60168-88-9 Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-(4-
chlorophenyl)-5-pyrimidinemethanol]
60207-90-1 Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl- 1,3-
dioxolan-2-yl]-methyl-1H-1,2,4,-triazole]
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
2-nitrobenzoic acid, sodium salt]
63938-10-3 Chlorotetrafluoroethane 1.0
64902-72-3 Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino] carbonyl]
benzenesulfonamide]
64969-34-2 3,3'-Dichlorobenzidine sulfate 0.1
66441-23-4 Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic
acid, ethyl ester]
67485-29-4 Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-
(trifluoromethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene]hydrazone]
68085-85-8 Cyhalothrin 1.0
[3-(2-Chloro-3,3,3-trifluoro-1-propenyl)-
2,2-dimethylcyclopropanecarboxylic acid
cyano(3-phenoxyphenyl) methyl ester]
68359-37-5 Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
69409-94-5 Fluvalinate 1.0
[N-[2-Chloro-4-
(trifluoromethyl)phenyl]DL-valine(+)-
cyano(3 -phenoxyphenyl)methyl ester]
69806-50-4 Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
71751-41-2 Abarriectiri[AvermectiriBl] 1.0
72178-02-0 Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
CAS Number Chemical Name
De minimis
% Limit
Arranged by CAS Number
N-methylsulfonyl)-2-nitrobenzamide]
72490-01-8 Fenoxycarb 1.0
[[2-(4-Phenoxy phenoxy)ethyl]carbamic
acid ethyl ester]
74051-80-2 Sethoxydim 1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl] -3 -hydroxyl-2-
cy clohexen-1 -one]
76578-14-8 Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-quinoxarinyl)
oxy]phenoxy]propanoic acid ethyl ester]
77501-63-4 Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
82657-04-3 Bifenthrin 1.0
88671-89-0 Myclobutanil 1.0
[.alpha.-Butyl-.alpha.-(4-chlorophenyl)-
1H-1,2,4-triazole-1 -propanenitrile]
90454-18-5 Dichloro-l,l,2-trifluoroethane 1.0
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-
2-yl)amino]carbonyl]
amino] sulfonyl]benzoate]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-
2-yl)methylamino]carbonyl]
amino] sulfonyl]benzoic acid methyl ester]
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine
hydrochloride)
127564-92-5 Dichloropentafluoropropane 1.0
128903-21-9 2,2-Dichloro-l, 1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
136013-79-1 1,3-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
c.
Chemical Categories
Section 313 requires reporting on the EPCRA Section 313
chemical categories listed below, in addition to the specific
EPCRA Section 313 chemicals listed above.
The metal compound categories listed below, unless otherwise
specified, are defined as including any unique chemical substance
that contains the named metal (e.g., antimony, nickel, etc.) as part
of that chemical's structure.
EPCRA Section 313 chemical categories are subject to the 1% de
minimis concentration unless the substance involved meets the
definition of an OSHA carcinogen in which case the 0.1% de
minimis concentration applies. The de minimis concentration for
each category is provided in parentheses. The de minimis
exemption is not available for PBT chemicals, therefore an
asterisk appears where a de minimis limit would otherwise appear.
Toxics Release Inventory Reporting Form and Instructions
11-18
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Table II. EPCRA Section 313 Chemical List - RY2009
However, for purposes of the supplier notification requirement only,
such limits are provided in Appendix D.
N010
N020
N040
Antimony Compounds (1.0)
Includes any unique chemical substance that contains
antimony as part of that chemical's infrastructure.
Arsenic Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that contains
arsenic as part of that chemical's infrastructure.
Barium Compounds (1.0)
Includes any unique chemical substance that contains
barium as part of that chemical's infrastructure. This
category does not include:
Barium sulfate CAS Number 7727-43-7
Beryllium Compounds (0.1)
Includes any unique chemical substance that
contains beryllium as part of that chemical's
infrastructure.
Cadmium Compounds (0.1)
Includes any unique chemical substance that
contains cadmium as part of that chemical's
infrastructure.
N084 Chlorophenols (0.1)
N050
N078
N090
N096
N100
Where x = 1 to 5
Chromium Compounds
(except for chromite ore mined in the Transvaal
Region of South Africa and the unreacted ore
component of the chromite ore processing residue
(COPR). COPR is the solid waste remaining after
aqueous extraction of oxidized chromite ore that has
been combined with soda ash and kiln roasted at
approximately 2,000 deg.F.)
(chromium VI compounds: 0.1; chromium III
compounds: 1.0)
Includes any unique chemical substance that contains
chromium as part of that chemical 's
infrastructure.
Cobalt Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that contains
cobalt as part of that chemical 's infrastructure.
Copper Compounds (1.0)
Includes any unique chemical substance that contains
copper as part of that chemical's infrastructure. This
category does not include copper phthalocyanine
compounds that are substituted with only hydrogen,
and/or chlorine, and/or bromine.
N106 Cyanide Compounds (1.0)
X^CN' where X = H+ or any other group where a
formal dissociation can be made. For example KCN
or Ca(CN)2.
N120 Diisocyanates (1.0)
This category includes only those chemicals listed
below.
38661-72-2 l,3-Bis(methylisocyanate) -
cyclohexane
10347-54-3 l,4-Bis(methylisocyanate)-
cyclohexane
2556-36-7 1,4-Cyclohexane
diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
4128-73-8 4,4'-Diisocyanatodiphenyl
ether
75790-87-3 2,4'-Diisocyanatodiphenyl
sulfide
91-93-0 3,3'-Dimethoxybenzidine-
4,4'-diisocyanate
91-97-4 3,3'-Dimethyl-4,4'-
diphenylene diisocyanate
139-25-3 3,3'-Dimethyldiphenyl
methane-4,4'-diisocyanate
822-06-0 Hexamethylene-1,6-
diisocyanate
4098-71-9 Isophorone diisocyanate
75790-84-0 4-Methyldiphenylmethane-3,4-
diisocyanate
5124-30-1 l,l-Methylenebis(4-
isocyanatocyclohexane)
101-68-8 Methylenebis(phenylisocyanate)
(MDI)
3173-72-6 1,5-Naphthalene
diisocyanate
123-61-5 1,3-Phenylene diisocyanate
104-49-4 1,4-Phenylene diisocyanate
9016-87-9 Polymeric diphenylmethane
diisocyanate
16938-22-0 2,2,4-Trimethylhexamethylene
diisocyanate
15646-96-5 2,4,4-Trimethylhexamethylene
diisocyanate
N150 Dioxin and Dioxin-Like Compounds
(Manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacturing of that
chemical.) (*) This category includes only those
chemicals listed below. [Note: When completing the
Form R Schedule 1, enter the data for each member of
Toxics Release Inventory Reporting Form and Instructions
11-19
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Table II. EPCRA Section 313 Chemical List - RY2009
the category in the order they are listed here (i.e., 1-17).]
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
2,3,7,8-
Tetrachlorodibenzo-p-dioxin
1,2,3,7,8-
Pentachlorodibenzo-p-dioxin
1,2,3,4,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-
Hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9-
Octachlorodibenzo-p-dioxin
2,3,7,8-
Tetrachlorodibenzofuran
1,2,3,7,8-
Pentachlorodibenzofuran
2,3,4,7,8-
Pentachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorod-benzofuran
1,2,3,6,7,8-
Hexachlorodibenzofuran
1,2,3,7,8,9-
Hexachlorodibenzofuran
2,3,4,6,7,8-
Hexachlorodibenzofuran
1,2,3,4,6,7,8-
Heptachlorodibenzofuran
1,2,3,4,7,8,9-
Heptachlorodibenzofuran
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
N450
N458
N495
N503
N511
N575
N583
N171 Ethylenebisdithiocarbamic acid, salts and esters
EBDCs) (1.0)
Includes any unique chemical substance that contains an
EBDC or an EBDC salt as part of that chemical's
infrastructure.
N230 Certain Glycol Ethers (1.0)
R-(OCH2CH2)n-OR'
where n= 1, 2, or 3
R = alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H, or alkyl C7 or less; or
OR= consisting of carboxylic acid ester, sulfate, phosphate, nitrate,
or sulfonate.
N420 Lead Compounds (*)
Includes any unique chemical substance that contains
N590
lead as part of that chemical's infrastructure.
Manganese Compounds (1.0)
Includes any unique chemical substance that contains
manganese as part of that chemical's infrastructure.
Mercury Compounds (*)
Includes any unique chemical substance that contains
mercury as part of that chemical's infrastructure.
Nickel Compounds (0.1)
Includes any unique chemical substance that contains
nickel as part of that chemical's infrastructure.
Nicotine and salts (1.0)
Includes any unique chemical substance that contains
nicotine or a nicotine salt as part of that chemical's
infrastructure.
Nitrate compounds (water dissociable; reportable
only when in aqueous solution) (1.0)
H(10-x)
Where x = 1 to 10
Polybrominated Biphenyls (PBBs) (0.1)
Polychlorinated alkanes (Ci0 to Ci3) (1.0, except for
those members of the category that have an average
chain length of 12 carbons and contain an average
chlorine content of 60% by weight which are subject
to the 0.1% de minimis)
where x= 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 C 70% with
the limiting molecular formulas CigH^C^ and
16C112
Polycyclic aromatic compounds (PACs) (*)
This category includes the chemicals listed below.
56-55-3 Benz(a)anthracene
205-99-2 Benzo(b)fluoranthene
205-82-3 Benzo(j)fluoranthene
207-08-9 Benzo(k)fluoranthene
206-44-0 Benzo(j,k)fluorene
189-55-9 Benzo(r,s,t)pentaphene
218-01-9 Benzo(a)phenanthrene
50-32-8 Benzo(a)pyrene
226-36-8 Dibenz(a,h)acridine
224-42-0 Dibenz(aj)acridine
53-70-3 Dibenzo(a,h)anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
Toxics Release Inventory Reporting Form and Instructions
11-20
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Table II. EPCRA Section 313 Chemical List - RY2009
5385-75-1
192-65-4
189-64-0
191-30-0
57-97-6
193-39-5
56-49-5
3697-24-3
5522-43-0
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7, 12-Dimethylbenz(a)-anthracene
Indeno( 1,2,3 -cd)pyrene
3 -Methy Icholanthrene
5-Methylchrysene
1-Nitropyrene
N725 Selenium Compounds (1.0)
Includes any unique chemical substance that contains
selenium as part of that chemical's infrastructure.
N740 Silver Compounds (1.0)
Includes any unique chemical substance that contains silver
as part of that chemical's infrastructure.
N746 Strychnine and salts (1.0)
Includes any unique chemical substance that contains
strychnine or a strychnine salt as part of that chemical's
infrastructure.
N760 Thallium Compounds (1.0)
Includes any unique chemical substance that contains
thallium as part of that chemical's infrastructure.
N770 Vanadium Compounds (1.0)
Includes any unique chemical substance that contains
vanadium as part of that chemical's
infrastructure.
N874 Warfarin and salts (1.0)
Includes any unique chemical substance that contains
warfarin or a warfarin salt as part of that chemical's
infrastructure.
N982 Zinc Compounds (1.0)
Includes any unique chemical substance that contains zinc
as part of that chemical's infrastructure.
Toxics Release Inventory Reporting Form and Instructions 11-21
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Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
Toxics Release Inventory Reporting Form and Instruction
III-l
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Table IV. Country Codes
AA
AC
AE
AF
AG
AJ
AL
AM
AN
AO
AR
AS
AT
AU
AV
AY
BA
BB
BC
BD
BE
BF
BG
BH
BK
BL
BM
BN
BO
BP
BR
BS
BT
BU
BV
BX
BY
CA
CB
CD
KE
KG
KN
KQ
KR
Aruba
Antigua and Barbuda
United Arab
Emirates
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and Cartier
Islands
Austria
Anguilla
Antarctica
Bahrain
Barbados
Botswana
Bermuda
Belgium
The Bahamas
Bangladesh
Belize
Bosnia and
Herzegovina
Bolivia
Burma
Benin
Belarus
Solomon Islands
Brazil
Bassas da India
Bhutan
Bulgaria
Bouvet Island
Brunei
Burundi
Canada
Cambodia
Chad
Kenya
Kyrgyzstan
North Korea
Kingman Reef
Kiribati
CE
CF
CG
CH
CI
CJ
CK
CM
CN
CO
CR
CS
CT
CU
CV
CW
CY
DA
DJ
DO
DR
EC
EG
El
EK
EN
ER
ES
ET
EU
EZ
FG
FI
FJ
FK
FO
FP
FR
KS
KT
KU
KZ
LA
Sri Lanka
Congo
(Brazzaville)
Congo (Kinshasa)
China
Chile
Cayman Islands
Cocos (Keeling)
Islands
Cameroon
Comoros
Colombia
Coral Sea Islands
Costa Rica
Central African
Republic
Cuba
Cape Verde
Cook Islands
Cyprus
Denmark
Djibouti
Dominica
Dominican
Republic
Ecuador
Egypt
Ireland
Equatorial Guinea
Estonia
Eritrea
El Salvador
Ethiopia
Europa Island
Czech Republic
French Guiana
Finland
Fiji
Falkland Islands
(Islas Malvinas)
Faroe Islands
French Polynesia
France
South Korea
Christmas Island
Kuwait
Kazakhstan
Laos
FS
GA
GB
GG
GH
GI
GJ
GK
GL
GM
GO
GP
GR
GT
GV
GY
GZ
HA
HK
HM
HO
HR
HU
1C
ID
IM
IN
IO
IP
IR
IS
IT
IV
IZ
JA
JE
JM
JN
JO
JU
LE
LG
LH
LI
LO
French Southern and
Antarctic Lands
The Gambia
Gabon
Georgia
Ghana
Gibraltar
Grenada
Guernsey
Greenland
Germany
Glorioso Islands
Guadeloupe
Greece
Guatemala
Guinea
Guyana
Gaza Strip
Haiti
Hong Kong
Heard Island and
McDonald Islands
Honduras
Croatia
Hungary
Iceland
Indonesia
Isle of Man
India
British Indian Ocean
Territory
Clipperton Island
Iran
Israel
Italy
Cote D'lvoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova Island
Lebanon
Latvia
Lithuania
Liberia
Slovakia
Toxics Release Inventory Reporting Form and Instructions
IV-1
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Table IV. Country Codes
LS
LT
LU
LY
MA
MB
MC
MD
MF
MG
MH
MI
MK
ML
MN
MO
MP
MR
MT
MU
MV
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
NO
NP
NR
NS
NT
NU
NZ
PA
PC
PE
Liechtenstein
Lesotho
Luxembourg
Libya
Madagascar
Martinique
Macau
Moldova
Mayotte
Mongolia
Montserrat
Malawi
Macedonia
Mali
Monaco
Morocco
Mauritius
Mauritania
Malta
Oman
Maldives
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
Norway
Nepal
Nauru
Suriname
Netherlands Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
PF
PG
PK
PL
PM
PO
PP
PS
PU
QA
RE
RO
RP
RS
RW
SA
SB
SC
SE
SF
SG
SH
SI
SL
SM
SN
SO
SP
ST
SU
sv
sw
sx
SY
SZ
TD
TE
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Palau
Guinea-Bissau
Qatar
Reunion
Romania
Philippines
Russia
Rwanda
Saudi Arabia
St. Pierre and
Miquelon
St. Kitts and Nevis
Seychelles
South Africa
Senegal
St. Helena
Slovenia
Sierra Leone
San Marino
Singapore
Somalia
Spain
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
Islands
Syria
Switzerland
Trinidad and
Tobago
Tromelin Island
TH
TI
TK
TL
TN
TO
TP
TS
TT
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC
VE
VI
VM
VT
WA
WE
WF
WI
WS
WZ
YI
YM
ZA
ZI
Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
East Timor
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina Faso
Uruguay
Uzbekistan
St. Vincent and the
Grenadines
Venezuela
British Virgin
Islands
Vietnam
Vatican City
Namibia
West Bank
Wallis and Futuna
Western Sahara
Western Samoa
Swaziland
Yugoslavia
Yemen
Zambia
Zimbabwe
IV-2
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Appendix A. TRI Federal Facility Reporting
Information
Special Instructions for TRI Federal
Facility Reporting
A.1 Why Do Federal
Facilities Need to Report?
Executive Order 13423, "Strengthening Federal
Environmental Energy, and Transportation
Management," requires federal agencies to comply
with the Emergency Planning and Community Right-
To-Know Act of 1986 (EPCRA) and the Pollution
Prevention Act of 1990 (PPA). Federal facilities have
been subject to EPCRA section 313 and PPA since
reporting year 1994. TRI submissions are due to EPA
on July 1 of the year following each reporting
(calendar) year. Reporting by the federal facility does
not alter the reporting obligation of on-site contractors.
Contracts entered into after the date of this order for
contractor operation of government-owned facilities or
vehicles require the contractor to comply with the
provisions of this order with respect to such facilities
or vehicles to the same extent as the agency would be
required to comply if the agency operated facilities or
vehicles.
For more information on Executive Order 13423 please
refer to the implementing instructions, which can be
found on the TRI home page at http://www.epa.gov/tri
A.2 Identifying Federal
Facility Reports
Federal facility reports are identified as federal by
several indicators on the form. The facility name and
parent company name are critical indicators and must
be reported as described below. Another critical
indicator is the federal facility report box, Part I, 4.2c.
Federal facilities only should check this box to indicate
that the report is from a federal agency for a federal
facility; federal facilities should not check the GOCO
box, (Part I, Section 4.2d of the Form R). Contractors
located at federal facilities (GOCOs) should check the
GOCO box (Part I, Section 4.2d of the Form R); they
should not check the box 4.2c. Facilities should also
complete the partial or complete facility blocks (Form
R page 2, block 4.2a and 4.2b) as appropriate. If you
are a federal facility reporting for the first time, you
should write "new" in the TRI Facility ID (TRIFID)
box, even if a contractor has reported for your facility
in the past. The contractor will retain the original
TRIFID. You will be assigned a new TRIFID the first
time you report.
A.3 The "Double
Counting" Problem
As structured, the law and the executive order require
both regulated industries and the federal government to
report TRI data, sometimes for the same site. In order
to prevent duplicate data in the TRI database, which
could result in "double counting" data for some
chemicals and locations, EPA must be able to identify
and distinguish the GOCO reports submitted by the
federal contractor from the federal facility reports
which contain data for the same site. To accomplish
this, federal facility reports should be accompanied by
either 1) exact copies (paper or electronic) of all
contractor TRI reports, including when the totals
reported by the federal facility are greater than that
reported by the contractor(s), or 2) a cover letter which
includes a list of the facility contractors which submit
TRI reports to EPA, identifying each contractor by
name, TRI technical contact, and TRI facility name and
address. Additionally, federal facilities should check
Form R, Part I, Section 4.2c, while contractors at
federal facilities should check Form R, Part I, Section
4.2d.
A.4 Magnetic Media
Reporting
All federal facilities are required to report using
Internet reporting. If the GOCO submits its reports on
magnetic media to EPA and to the federal facility, the
federal facility may submit magnetic media copies of
their GOCO TRI reports to EPA provided that those
reports account for all subject activities at the facility.
Magnetic media reports must be accompanied by a
cover letter which includes:
• Required Form R certification statement;
• List of the chemicals reported on the federal
facility's disk; and
• List that identifies the contractor(s) [if any] by
name and by TRIFID number if they have an
assigned TRIFID number, and the chemicals
they reported (which are on the contractors'
attachment disk(s)).
Toxics Release Inventory Reporting Forms and Instructions
A-l
-------
Appendix A
A.5 How to Report Your
Facility Name
Facility name is a critical data element. It is used by
EPA to create the TRI facility ID number (TRIFID),
which is a unique number designed to identify a facility
site. The facility name and TRIFID number are used
by all TRI data users to link data from a single site
across multiple reporting years. A federal facility is
assigned a new TRIFID number when the federal
report is entered into the Toxics Release Inventory
system for the first time. This TRIFID number,
generated when the first report is entered into the
Toxics Release Inventory System, will be included in
future reporting packages sent to the federal facility,
and should be used by the federal facility in all future
reports.
Federal facilities should report their facility name on
page 1 of the Form Rs (Section 4.1), as shown in the
following example:
U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.
Federal contractors at GOCO facilities should report
their names as shown in the following example:
U.S. DOE Savannah River Site -
Westinghouse Operations.
A.6 How to Report Your
North American Industry
Classification System
(NAICS) Code
Federal facilities should report the NAICS code which
most closely represents the activities taking place at the
site. Additional guidance on determining your NAICS
code is provided in the Forms and Instructions booklet.
The table on the next page contains Public
Administration NAICS codes covering executive,
legislative, judicial, administrative and regulatory
activities of the Federal government. Government-
owned and operated business establishments are
classified in major NAICS groups according to the
activity in which they are engaged. For example, a
Veterans Hospital would be classified in Group 806 -
Hospitals.
A.7 How to Report Your
"Parent Company" Name
Federal facilities should report their parent company
name on page 2 of the Form Rs (Section 5.1) by
reporting their complete Department or Agency name,
as shown in the following example:
U.S. Department of Energy
Block 5.2, Parent Company's Dun & Bradstreet
Number, should be marked NA.
Federal contractors at GOCO facilities should not
report a federal department or agency name as their
parent company. A federal name in the parent
company name field will classify the report as federal,
and the GOCO may be identified as a non-reporter.
A.8 How to Revise Your
Data After It Has Been
Submitted
Any TRI Form R submitter may voluntarily revise their
submission if they find errors after their reports have
been sent to EPA. If the revision is to a hardcopy
report, the facility reporter should photocopy the
original form and use a blue or black pen to mark out
the incorrect value and write in the corrected value.
The revised report should be submitted to EPA, with an
"X" in the revision block on page 1 of the Form R. If
the revision is to a diskette, a new diskette should be
submitted, containing the data only for the revised
submission, not all the chemicals originally reported. If
a federal facility receives a copy of a revision from a
contractor located at the federal facility, the facility
should revise the federal report, and submit the revised
report to EPA and the appropriate state along with an
exact copy of the contractor's revision. The cover
letter from the federal facility should indicate that its
submission is a revision.
A.9 Who Should Sign
Federal Form R Reports?
Federal Form R reports should be signed by the senior
federal employee on-site. If no federal employee is on-
site, federal Form R reports must be signed by the
senior federal employee with management
responsibility for the site. Federal Form R reports
should be signed by a federal employee. Contractor
employee signatures are not considered valid on federal
reports.
A-2
Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix A
A.10 More Help is
Available!
Federal facilities may call the EPA/TRI Information
Center to ask specific questions concerning how to
submit their Form R report. For contact information,
see the TRI Home Page at http://www.epa.gov/tri/
A.11 North American
Industry Classification
System Codes 921-928
Sector 92 - Public Administration
921 Executive, Legislative, and Other
General Government Support
92111 Executive Offices
92112 Legislative Bodies
92113 Public Finance Activities
92114 Executive and Legislative Offices Combined
92115 American Indian and Alaska Native Tribal
Governments
92119 General Government, Not Elsewhere
Classified
922 Justice, Public Order, and Safety
Activities
92211 Courts
92212 Police Protection
92213 Legal Counsel and Prosecution
92214 Correctional Institutions
92215 Parole Offices and Probation Offices
92216 Fire Protection
92219 Other Justice, Public Order and Safety
Activities
923 Administration of Human Resource
Programs
92311 Administration of Educational Programs
92312 Administration of Public Health Programs
92313 Administration of Human Resource Programs
(Except Education, Public Health, and
Veterans' Affairs Programs)
92314 Administration of Veterans Affairs
924 Administration of Environmental
Quality Programs
92411 Administration of Air and Water Resource
and Solid Waste Management Programs
92412 Administration of Conservation Programs
925 Administration of Housing
Programs, Urban Planning, and
Community Development
92511 Administration of Housing Programs
92512 Administration of Urban Planning and
Community and Rural Development
926 Administration of Economic
Programs
92611 Administration of General Economic
Programs
92612 Regulation and Administration of
Transportation Programs
92613 Regulation and Administration of
Communications, Electric, Gas, and Other
Utilities
92614 Regulation of Agricultural Marketing and
Commodities
92615 Regulation, Licensing, and Inspection of
927
92711
928
Affairs
Miscellaneous Commercial Sectors
Space Research and Technology
Space Research and Technology
National Security and International
92811 National Security
92812 International Affairs
Toxics Release Inventory Reporting Forms and Instructions
A-3
-------
Appendix B. Reporting Codes for EPA Form R
and Instructions for Reporting Metals
B.1 Form R Part
Revision Codes:
RRl New Monitoring Data
RR2 New Emission Factor(s)
RR3 New Chemical Concentration Data
RR4 Recalculation(s)
RR5 Other Reason(s)
Withdrawal Codes:
N760 Thallium compounds
N770 Vanadium compounds
N874 Warfarin and salts
N982 Zinc compounds
Section 4. Maximum Amount of the
Toxic Chemical On-Site at Any Time
During the Calendar Year
Range(pounds)
WT 1 Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
WT2 Did not meet the reporting threshold for number
of employees
WT3 Not in a covered NAICS Code
WO1 Other reason(s)
Section 1.1. CAS Number
EPCRA Section 313 Chemical Category
o */
Codes
NO 1 0 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N17 lEthylenebisdithiocarbamic
acid, salts and esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N5 1 1 Nitrate compounds
N575 Polybrominatedbiphenyls(PBBs)
N583 Polychlorinated alkanes
N590 Poly cyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
Range Code From To
m n oo
Ul U yy
02 100 999
m i nnn o ooo
UJ 1,UUU y,yyy
04 10,000 99,999
05 100,000 999,999
06 1,000,000 9,999,999
07 10,000,000 49,999,999
08 50,000,000 99,999,999
09 100,000,000 499,999,999
10 500,000,000 999,999,999
11 1 billion more than 1 billion
Section 5. Quantity of the Non-PBT
Chemical Entering Each Environmental
Medium On-site and Section 6.
Transfers of the Toxic Chemical in
Wastes to Off-Site Locations
Total Release or Transfer
Code Range (pounds)
A 1-10
B 11-499
C 500-999
Basis of Estimate
Ml - Estimate is based on continuous monitoring
data or measurements for the EPCRA
section 313 chemical.
M2- Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA section 313 chemical.
Toxics Release Inventory Reporting Forms and Instructions
B-l
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Appendix B
C- Estimate is based on mass balance calculations,
such as calculation of the amount of the EPCRA
section 313 chemical in streams entering and
leaving process equipment.
El - Estimate is based on published emission factors,
such as those relating release quantity to
through-put or equipment type (e.g., air emission
factors).
E2- Estimate is based on site specific emission
factors, such as those relating release quantity to
through-put or equipment type (e.g., air emission
factors).
O- Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a waste stream, even if the
composition of the stream before treatment was
fully identified through monitoring data.
Section 6. Transfers of the Toxic Chemical
in Wastes to Off-Site Locations
Type of Waste Disposal/Treatment/Energy
Recovery/Recycling
M10 Storage Only
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M40 Solidification/Stabilization
M41 Solidification/Stabilization-Metals and Metal
Category Compounds only
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M56 Energy Recovery
M61 Wastewater Treatment (Excluding POTW)
M62 Wastewater Treatment (Excluding POTW) C
Metals and Metal Category Compounds only
M64 Other Landfills
M65 RCRA Subtitle C Landfills
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
M69 Other Waste Treatment
M73 Land Treatment
M79 Other Land Disposal
M81 Underground Injection to Class I Wells
M82 Underground Injection to Class II-V Wells
M90 Other Off-Site Management
M92 Transfer to Waste Broker C Energy Recovery
M93 Transfer to Waste Broker C Recycling
M94 Transfer to Waste Broker C Disposal
M95 Transfer to Waste Broker C Waste
Treatment
M99 Unknown
Section 7A. On-Site Waste Treatment
Methods and Efficiency
General Waste Stream
A Gaseous (gases, vapors, airborne
particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and
slurries)
Waste Treatment Methods
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Chemical Treatment
H040 Incineration-thermal destruction other than
use as a fuel
H071 Chemical reduction with or without
precipitation
H073 Cyanide destruction with or without
precipitation
H075 Chemical oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or without
pre-treatment
Biological Treatment
H081 Biological treatment with or without
precipitation
Physical Treatment
H082 Adsorption
H083 Air or steam stripping
H101 Sludge treatment and/or dewatering
H103 Absorption
Hill Stabilization or chemical fixation prior to
disposal
HI 12 Macro-encapsulation prior to disposal
H121 Neutralization
HI 22 Evaporation
H123 Settling or clarification
HI24 Phase separation
H129 Other treatment
B-2
Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
Section 7B. On-Site Energy Recovery
Processes
UOl Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
Section 7C. On-Site Recycling Processes
H10 Metal recovery (by retorting, smelting, or
chemical or physical extraction)
H20 Solvent recovery (including distillation,
evaporation, fractionation or extraction)
H3 9 Other recovery or reclamation for reuse
(including acid regeneration or other chemical
reaction process)
Section 8.10. Source Reduction Activity
Codes
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do
not stay in inventory beyond shelf-life
W22 Began to test outdated material C continue to use
if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials
that would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading, and
transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W3 5 Installed vapor recovery systems
W36 Implemented inspection or monitoring program
of potential spill or leak sources
W39 Other changes made in spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted recirculation within a process
W52 Modified equipment, layout, or piping
W53 Use of a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to
bulk containers to minimize discarding of
empty containers
W58 Other process modifications
Cleaning and Degreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning
devices (from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents
or other materials)
W63 Modified containment procedures for
cleaning units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and degreasing
modifications
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of products
W83 Modified packaging
W89 Other product modifications
Section 8.10. Methods Used to Identify
Source Reduction Activities
For each source reduction activity, enter up to three of
the following codes that correspond to the method(s)
which contributed most to the decision to implement
that activity.
TO 1 Internal Pollution Prevention Opportunity
Audit(s)
T02 External Pollution Prevention Opportunity
Audit(s)
T03 Materials Balance Audits
T04 Participative Team Management
Toxics Release Inventory Reporting Forms and Instructions
B-3
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Appendix B
T05 Employee Recommendation (independent of a T08 Federal Government Technical Assistance
formal company program) Program
T06 Employee Recommendation (under a formal T09 Trade Association/Industry Technical
company program) Assistance Program
T07 State Government Technical Assistance Program T10 Vendor Assistance
Til Other
B-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
B.2 Reporting the Waste Management of Metals
This appendix outlines how the TRI-ME reporting software restricts reporting for metals when the specific data element or
waste management code is not applicable for a particular chemical. Below is a list of metals divided into four groups along
with charts that help explain where quantities of these chemicals can and can not be reported on the Form R using TRI-ME.
In addition, there are charts that explain restrictions on reporting waste management codes for the toxic chemicals in each of
the four groups. This appendix only shows where reporting is restricted in TRI-ME, it does not indicate every situation where
a metal should not be reported in a specific section of the form. For example, TRI-ME does not restrict the reporting of most
individually-listed metal compounds as used for energy recovery (Sections 8.2 and 8.3) even though some of these chemicals
do not have a heat value greater that 5000 British thermal units (Btu) and, thus, can not be combusted for energy recovery. It
is left to the facility to decide which of these toxic chemicals can be used for energy recovery. If you are not using TRI-ME
this appendix can serve as a guide to help you understand where it is not appropriate to report certain quantities of toxic
chemicals or waste management codes on your Form R.
Parent Metals:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:
Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium Compounds
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds
Metals with
Qualifiers:
Aluminum (fume or dust)
Vanadium (except when
in an alloy)
Zinc (fume or dust)
Individually-Listed
Metal Compounds:
Bis(tributylin) oxide
Triphenyltin hydroxide
Triphenyltin chloride
Molybdenum trioxide
Thorium dioxide
Asbestos (friable)
Aluminum oxide (fibrous
forms)
Tributyltin fluoride
Tributyltin
methacrylate
Titanium
tetrachloride
Boron trifluoride
Metiram
Boron trichloride
Zineb
Maneb
Fenbutatin oxide
Iron pentacarbonyl
Ferbam
C.I. Direct Brown
95
Osmium tetroxide
Aluminum
phosphide
C.I. Direct Blue
218
Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTWs
The following chart indicates which metals can be reported as released to water in Section 5.3 or to POT W' s in Section 6.1.
Only zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust form of a
toxic chemical can not exist in water.
Form R Section in
Part II
Section 5. 3 -
Discharges to
receiving streams or
water bodies
Section 6.1-
Discharges to
POTWs
Parent Metals
All
All
Metal Category
Compounds
All
All
Metals with
Qualifiers
Vanadium (except
when contained in an
alloy)
Vanadium (except
when contained in an
alloy)
Individually-listed
Metal Compounds
All except Asbestos
All except Asbestos
Toxics Release Inventory Reporting Forms and Instructions
B-5
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Appendix B
Section 6.2. Transfers to Other Off-Site Locations
Any toxic chemical may be reported in Section 6.2. However, TRI-ME will not allow certain M codes to be used when
reporting metals. The chart below indicates which M codes can be reported in Section 6.2 for the four groups of metals.
Note that all disposal M codes other than M41 and M62 can be used for all toxic chemicals. Code M24 is only made
available for the four groups of metals.
Waste Management Code for
Section 6.2
M41 and M62 (disposal codes-for
metals only)
M56 and M92 (energy recovery
codes)
M20 and M28 (recycling codes)
M24, M26 and M93 (recycling
codes)
M40, M50, M54, (treatment codes)
M61, M69, M95 (treatment codes)
Parent
Metals
All
None
None
All
None
Barium2
Metal Category
Compounds
All
None
None
All
None
Barium
Compounds2
Metals with
Qualifiers
Vanadium (except
when contained in an
alloy)
None
None
All
All except Vanadium
(except when
contained in an alloy)
Same as above
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos1
All
All
All
All
Section 7A. On-site Waste Treatment Methods and Efficiency
TRI-ME allows any toxic chemical to be reported in Section 7A, however, it limits reporting in two ways. First, TRI-ME
limits the treatment codes that can be reported based on the General Waste Stream Code selected. If a TRI-ME user selects
General Waste Stream code "A - Gaseous", all Waste Treatment Codes are made available. However, if a user selects from
the remaining three General Waste Stream Codes (W - Wastewater, L - Liquid waste streams, or S - Solid waste streams), the
"Air Emissions Treatment" Waste Treatment Codes are not made available. Second, the software restricts reporting for
certain toxic chemicals with qualifiers. When reporting zinc (fume or dust) or aluminum (fume or dust) TRI-ME will not
allow the user to select General Waste Stream Codes W-Wastewater and L-Liquid waste streams because the fume or dust
form of a toxic chemical can not exist in a liquid or water waste. For asbestos (friable) only S - Solid or A - Gaseous can be
selected. When reporting hydrochloric acid (acid aerosols) or sulfuric acid (acid aerosols) only A - Gaseous can be selected.
Crosswalk for Section 7 A, Column B. Waste Treatment Method (s) Sequence
Air Emissions Treatment (applicable to gaseous waste streams only)
(No change — same as previous codes)
A01
A02
A03
A04
A05
A06
A07
Flare
Condenser
Scrubber
Absorber
Electrostatic Precipitator
Mechanical Separation
Other Air Emission Treatment
B-6
Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
Biological Treatment:
Previous Codes
Bll
B21
B31
B99
Aerobic
Anaerobic
Facultative
Other Biological
Treatment
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H081
H081
H081
H081
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Chemical Treatment:
Previous Codes
C01
C02
C09
Cll
C21
C31
C41
C42
C43
C44
C45
C46
C99
Chemical Precipitation B
Lime or Sodium Hydroxide
Chemical Precipitation B
Sulfide
Chemical Precipitation B
Other
Neutralization
Chromium Reduction
Complexed Metals
Treatment (other than pH
adjustment)
Cyanide Oxidation B
Alkaline Chlorination
Cyanide Oxidation B
Electrochemical
Cyanide Oxidation B Other
General Oxidation
(including Disinfection) B
Chlorination
General Oxidation
(including Disinfection) B
Ozonation
General Oxidation
(including Disinfection) B
Other
Other Chemical Treatment
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H071
H071
H077
H121
H071
H129
H073
H073
H073
H075
H075
H075
H129
Chemical reduction with or without precipitation
Chemical reduction with or without precipitation
Other chemical precipitation with or without pre-
treatment
Neutralization
Chemical reduction with or without precipitation
Other treatment
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Chemical oxidation
Chemical oxidation
Chemical oxidation
Other treatment
Toxics Release Inventory Reporting Forms and Instructions
B-7
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Appendix B
Chemical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
Incineration/Thermal Treatment: (Note: Only report combustion for the purposes of incineration/thermal
treatment in Section 7 A. If the method involves combustion for the purposes of energy recover, report as UO 1 ,
U02, or U03 in Section 7B . If the method involves combustion for the purposes of materials recovery, report as
H39 in Section 7C.)
F01
Fll
F19
F31
F41
F42
F51
F61
F71
F81
F82
F83
F99
Liquid Injection
Rotary Kiln with Liquid
Injection Unit
Other Rotary Kiln
Two Stage
Fixed Hearth
Multiple Hearth
Fluidized Bed
Infra-Red
Fume/Vapor
Pyrolytic destructor
Wet air oxidation
Thermal Drying/Dewatering
Other Incineration/Thermal
Treatment
H040
H040
H040
H040
H040
H040
H040
H040
H040
H040
H076
H122
H040
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Wet air oxidation
Evaporation
Incineration B thermal destruction other than use as a
fuel
Physical Treatment:
Previous Codes
P01
P09
Pll
P12
P13
P14
P15
P16
P17
Equalization
Other blending
Settling/clarification
Filtration
Sludge dewatering (non-thermal)
Air flotation
Oil skimming
Emulsion breaking B thermal
Emulsion breaking B chemical
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H129
H129
H123
H123
H101
H124
H124
H124
H124
Other treatment
other treatment
Settling or clarification
Settling or clarification
Sludge treatment and/or dewatering
Phase separation
Phase separation
Phase separation
Phase separation
B-8
Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
Physical Treatment:
Previous Codes
P18
P19
P21
P22
P23
P29
P31
P41
P42
P49
P51
P61
P99
Emulsion breaking B other
Other liquid phase separation
Adsorption B Carbon
Adsorption B Ion exchange (other
than for recovery/reuse)
Adsorption B Resin
Adsorption B Other
Reverse Osmosis (other than for
recover/reuse)
Stripping B Air
Stripping B Steam
Stripping B Other
Acid Leaching (other than for
recovery/reuse)
Solvent Extraction (other than
recovery/reuse)
Other Physical Treatment
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H124
H124
H082
H082
H082
H082
H129
H083
H083
H083
H129
H129
H129
Phase separation
Phase separation
Adsorption
Adsorption
Adsorption
Adsorption
Other treatment
Air or steam stripping
Air or steam stripping
Air or steam stripping
Other treatment
Other treatment
Other treatment
Solidification/Stabilization:
Previous Codes
G01
G09
Gil
G20
G99
Cement processes
(including silicates)
Other Pozzolonic
Processes (including
silicates)
Asphaltic Techniques
Thermoplastic
Techniques
Other Solidification
Processes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
Hill
Hill
Hill
Hill
Hill
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Section 7B. On-site Energy Recovery Processes
The chart below indicates which energy recovery codes can be reported in TRI-ME in Section 7B for the four groups of
metals.
Energy Recovery Code for Section
7B
U01,U02,U03
Parent
Metals
None
Metal
Category
Compounds
None
Metals with
Qualifiers
None
Individually-
listed Metal
Compounds
All except
Asbestos1
Toxics Release Inventory Reporting Forms and Instructions
B-9
-------
Appendix B
Section 7C. On-site Recycling Processes
Any chemical can be reported in Section 1C. However, certain waste management codes should not be reported for certain
toxic chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-ME.
Recycling Code for Section 7C
H10(this code is for metals only
H20
H39
Parent
Metals
All
None
All
Metal Category
Compounds
All
None
All
Metals with
Qualifiers
All
None
All
Individually-
listed Metal
Compounds
All
All
All
Crosswalk for Section 7C. On-site Recycling Processes
Previous Codes
Rll
R12
R13
R14
R19
R21
R22
R23
R24
R26
R27
Solvents/Organics Recovery B
Batch Still Distillation
Solvents/Organics Recovery B
Thin-Film Evaporation
Solvents/Organics Recovery B
Fractionation
Solvents/Organics Recovery B
Solvent Extraction
Solvents/Organics Recovery B
Other
Metals Recovery B
Electrolytic
Metals Recovery B Ion
Exchange
Metals Recovery B Acid
Leaching
Metals Recovery B Reverse
Osmosis
Metals Recovery B Solvent
Extraction
Metals Recovery B High
Temperature
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H20
H20
H20
H20
H20
H10
H10
H10
H10
H10
H10
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
B-10
Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
Previous Codes
R28
R29
R30
R40
R99
Metals Recovery B Retorting
Metals Recovery B Secondary
Smelting
Metals Recovery B Other
Acid Regeneration
Other Reuse or Recovery
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H10
H10
H10
H39
H39
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Section 8. Source Reduction and Recycling Activities
The chart below indicates which metals can be reported in Sections 8.2,8.3,8.6 and 8.7 of the Form R when using TRI-ME.
Note that all toxic chemicals can be reported in Sections 8.1, 8.4, 8.5 and 8.8.
Waste Management Activity
Quantity used for energy recovery
on site and off site (Sections 8.2
and 8.3)
Quantity treated for destruction on
site and off site (Sections 8.6 and
8.7)
Parent
Metals
None
None
except
Barium2
Metal Category
Compounds
None
None except
Barium
Compounds2
Metals with
Qualifiers
None
All except
Vanadium
(except when
contained in an
alloy)
Individually-
listed Metal
Compounds
All except
Asbestos2
All
1 Although TRI-ME does not restrict reporting of most individually-listed metal compounds as transferred off site for
energy recovery, only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device
that is an industrial furnace or boiler (40 CFR Section 372.3) should be reported as used for energy recovery.
2 The toxic chemical category barium compounds (N040) does not include barium sulfate. Because barium sulfate is not a
listed toxic chemical, the conversion in a waste stream of barium or barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
Toxics Release Inventory Reporting Forms and Instructions
B-ll
-------
Appendix C. Facility Data Profiles and Common
Errors in Completing Form R Reports and Form A
Certification Statements
EPA wishes to ensure that facilities submit all required TRI
chemical submissions in a timely manner so that the
information may be included in its national database, National
Analysis (formerly called the public Data Release (PDR)), and
other information products. Moreover, EPA seeks to ensure
that all submitted data are complete and accurate. This
appendix provides an overview of the Facility Data Profile
(FDP), an important communication tool that EPA uses to
ensure consistent, complete, and accurate submissions from
reporting facilities. This appendix also provides specific
guidance to avoid common errors in completing Form Rs and
Form A Certification Statements, including errors in threshold
determination, misapplication of exemptions, and activities
involving a reportable chemical, any of which may result in the
erroneous non-reporting of a chemical.
C.1 Facility Data Profile
(FDP)
FDPs are made available by the TRI Data Processing Center
to a reporting facility in response to any submission the TRI
Data Processing Center receives. You may review your FDP
on the Internet at http://www.triefdp.org. It is very important
that you review your FDP. If the Technical Contact provided
an email address in the Form R/Form A, they will receive a
real-time email notifying them when their FDP has been
updated and posted to the FDP Web site. A submission can
include an original or revised Form R or Form A, or
corrections included in a response to a previous FDP. The
FDP serves two primary purposes. First, EPA wants to give
the reporting facility the opportunity to confirm that the TRI
Data Processing Center has entered its data correctly into
EPA's national computer system i.e. the TRI Data Processing
Center echoes back the information that it has received.
Second, if the TRI Data Processing Center identifies potential
errors in the forms a facility has submitted, the FDP indicates
what these errors are and requests that the facility provide EPA
with corrections. The FDP does not serve as a means to
withdraw a Form R and/or Form A. For additional information
regarding withdrawal procedures see Section A.5 of this
document or go to http://www.epa.gov/tri. If you have
questions regarding your FDP, please send an email to
tridpc@epacdx.net or call,(703) 227-7644. Facilities that send
corrections in response to their FDPs are encouraged to submit
a revision using CDX. For additional instructions regarding
your FDP, please refer to your FDP.
An FDP is comprised of the following sections:
• Facility Information. This section displays all
facility-specific data, including TRI Facility
Identification (TRIFID), facility name, facility
address, facility mailing address, relevant permits
(e.g., RCRA, NPDES, and UIC), North American
Industry Classification System code (NAICS), and
other facility data. Errors related to facility
information will be marked in this section.
• Instructions Page. This page provides instructions
on how to review and respond to the FDP.
• Certification Statement Signature Page. This page
provides the Certification Statement to be signed by a
facility owner/operator or senior management official
if using the FDP to make a revision.
• Chemical Report Summary. This section lists all
chemicals reported by the facility for each reporting
year covered by the FDP. For example, if the FDP is
responding to five original chemical submissions for
Reporting Year 2009 and revisions to one chemical
for Reporting Year 2007, a list of all chemicals for
both years will appear.
• Errors/Alerts Identified In This Report: Non-
Technical Data Changes (NDC), Notices of
Technical Errors (NOTE), Notices of Significant
Error (NOSE), and Data Quality Alerts (DQA).
FDPs identify three different types of errors: NDCs,
NOTEs and NOSEs and one type of alert called Data
Quality Alert (DQA). See explanations in section B.
• Error Summary Page. The Error Summary Page
provides facilities an error/alert count for each
chemical submission.
• Chemical Reports. All recently submitted and
processed Form R or Form A data (i.e., chemical
specific data) are displayed in the chemical reports
under the appropriate facility or subordinate facility
names. The FDP displays facsimiles for chemical
reports for submissions received during the current
calendar year and revisions or responses to FDPs
only. For example, if a facility originally reported
five chemicals for Reporting Year 2009, and
subsequently revises only one chemical submission,
the facility will receive an FDP for Reporting Year
2009 with only the revised chemical included in the
Chemical Reports section. Hence there may be fewer
chemical reports than chemicals listed in the
Chemical Summary section. If only facility level
Toxics Release Inventory Reporting Forms and Instructions
C-l
-------
Appendix C
changes have occurred (i.e., Part I of the Form R or
A), this section is not provided.
C.2 Levels of Errors
Identified in FDPs: Notice of
Non-Technical Data Change
(NDC), Notice of Technical
Errors (NOTE), Notice of
Significant Errors (NOSE),
Notice of Noncompliance
(NON)
FDP Error Reporting. In addition to echoing back the
information a facility has submitted, FDPs are used to identify
potential errors and provide Data Quality Alerts, as well as
indicate where the TPJ Data Processing Center has made
minor clerical changes to submissions. As submission
information is entered into EPA's national database, a series of
automated data quality checks are performed. The data quality
checks are useful to identify potential errors with certain data
fields such as TPJ Facility Identification, facility name, county
spelling, as well as to perform validation checks to ensure
consistency among data elements within a given Form R or
Form A. These data quality checks, however, cannot detect
whether release, transfer, or waste management quantities were
calculated or entered accurately. Within a FDP notice, there
may be up to three different types of errors identified.
TRI-MEweb Error Reporting. One of the advantages of
using the online electronic TRI-MEweb reporting system is that
it will notify submitters of several classes of common errors,
decreasing the potential for reporting errors on the initial
submission that will have to be corrected later.
First, a Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that the TPJ Data Processing Center has
corrected for you. It is not necessary to respond to a NDC.
The TRI Data Processing Center will correct simple, clerical
errors that are not technical or scientific - a "non-technical
data change." For example, if a facility transposes CAS
numbers (e.g., the submitter lists 7623-00-0 for sodium nitrite
instead of 7632-00-0), the TPJ Data Processing Center will
correct this clerical error and display the correct information
on the facility's FDP. If a facility lists a specific glycol ethers
subcategory, the TPJ Data Processing Center will replace this
subcategory with the reportable name Acertain glycol ethers."
The messages used on FDPs to report non-technical data
changes are shown at the end of this appendix under the
heading AE. Messages Used to Report Notices of Technical
Errors (NOTEs) and Non-technical Data Changes (NDCs)."
Second, a Notice of Technical Error (NOTE) highlights
inconsistencies or miscalculations that may distort your
facility's information in EPA's public data products or skew
analyses. Incomplete addresses, no technical or public contact
provided, missing or invalid NAICS codes, or the use of range
codes to report PBT chemical releases are all examples of
technical errors. You should respond to NOTEs as soon as
possible. These types of errors require that the reporting
facility make corrections on its FDP (or provide the TPJ Data
Processing Center with a brief explanation why they do not
believe that it is an error) or submit a revised Form R or Form
A. Depending upon when your changes are received, there
may or may not be sufficient time to incorporate them into
EPA's database in time for public data release. Technical
errors do not prevent submissions from being entered into the
data management system, but indicate inconsistencies or
miscalculations in the submitted form. These errors can distort
public information products and skew any analyses if not
corrected. The messages used on FDPs to report NOTEs are
shownbelow at the end of this appendix under the heading "D.
Messages Used to Report Notices of Technical Errors
(NOTEs) and Non-technical Data Changes (NDCs)."
Third, more serious errors are classified as Notices of
Significant Errors (NOSE). The FDP contains the Notice of
Significant Error if applicable. Significant errors prevent
submissions from being entered into the TRI Data Processing
Center data management system or do not allow the TPJ Data
Processing Center to verify the authenticity of the submission.
Invalid forms, missing pages, no certification signature, no
chemical name or CAS number are examples of significant
errors. These types of errors require that the reporting facility
make corrections on their FDP, submit a revised Form R or
Form A, or provide the TRI Data Processing Center with a
brief explanation why they do not believe that it is an error. A
facility must respond to a Notice of Significant Error within 21
days of receipt. Failure to respond within the initial 21 day
requirement could result in the issuance of a Notice of
Noncompliance (NON). A Notice of Noncompliance is not
included in a FDP and is mailed separately.
The Agency will issue a Notice of Noncompliance (NON) to
a facility for failure to respond to a Notice of Significant Error
(NOSE) within the required period. A NON will require a
facility to take the corrective action noted in the NOSE within
30 days and respond to the Agency that corrective action has
been taken. If a facility fails to respond to the NON within the
required time period, the Agency may take further action.
Facilities must keep copies, for three years, of submitted Form
R reports and Form A certifications and all documentation
used to complete their submissions. This documentation
should include calculations for threshold determinations, the
basis of exemptions applied, and the estimation techniques and
data used for all quantities reported on the Form R and Form
A.
For the first time beginning with RY 2004, TRI will provide
Data Quality Alerts (DQA). The DQA informs facilities of
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Appendix C
possible reporting issues, such as a large percentage change in
reported amounts of the same chemical between years. It is
offered to assist facilities in ensuring accurate reporting.
C.3 Common Errors in
Completing Form R Reports
and Form A Certification
Statements, including
Reporting Determination
Errors
General Considerations
• Lack of signed Certification Statement. If you
choose not to send your TRI submissions via the
paperless CDX process, you must sign Part I, Section
3 of your hard copy submission. Although EPA
accepts paper submissions, EPA strongly encourages
you to send your submission via CDX.
• Incomplete Forms. A complete Form R report for a
single EPCRA section 313 chemical or single
EPCRA section 313 chemical category consists of
five pages stapled together. By using TRI-MEweb
and CDX, errors such as this would not occur. Each
chemical submission must have its own page one.
EPA cannot enter into the database data from a
package that contains only one page 1, but several
page 2s, 3s, 4s, and/or 5s. Suchforms are considered
incomplete submissions.
Threshold Determinations
• Calculating threshold determinations. Annual
quantities manufactured, processed, or otherwise
used for section 313 chemicals must be calculated,
not surmised. The assumption that thresholds are
exceeded commonly leads to error.
• Misclassification of EPCRA section 313 chemical
activity. Failure to correctly classify an EPCRA
section 313 chemical activity may result in an
incorrect threshold determination. As a result, a
facility may fail to submit the required Form R.
• EPCRA section 313 chemical activity overlooked.
Many facilities believe that because the section 313
reporting requirement pertains to manufacturers, only
the use of EPCRA section 313 chemicals in
manufacturing processes must be examined. Any
activity involving the manufacture, process, or
otherwise use of an EPCRA section 313 chemical or
chemical category must be included in threshold
determinations. Commonly overlooked activities
include importation of chemicals, generation of waste
byproducts, processing of naturally occurring metals
and metal category compounds in ore, manufacturing
and processing intermediates, the use of chemicals
for cleaning of equipment, and the generation of
byproducts during combustion of coal and/or oil.
Facilities should take a systematic approach to
identify all chemicals and mixtures used in
production and non-production capacities, including
catalysts, well treatment chemicals, and wastewater
treatment chemicals.
Considering EPCRA section 313 chemicals in
mixtures and other trade name products. EPCRA
section 313 chemicals contained in mixtures
(including ores and stainless steel alloys) and other
trade name products must be factored into threshold
determinations and release and other waste
management determinations, provided that the de
minimis exemption cannot be taken. When the
EPCRA section 313 chemical being reported is a
component in a mixture or other trade name product,
report only the weight of the EPCRA section 313
chemical in the mixture. Refer to Section B.4b of this
document to calculate the weight of an EPCRA
section 313 chemical in a mixture or other trade name
product.
Overlooking manufacturing. Coincidental
manufacturing must not be overlooked. If coal and/or
fuel oil and other raw materials that contain EPCRA
section 313 chemicals are used in boilers/burners,
there is a potential for the coincidental manufacture
of EPCRA section 313 chemicals such as sulfuric
acid (acid aerosols), hydrochloric acid (acid
aerosols), hydrogen fluoride, and metal category
compounds. Additionally, manufacturing of EPCRA
section 313 chemicals during waste treatment is
commonly overlooked. For example, the treatment of
nitric acid may result in the manufacturing of a
reportable chemical (nitrate compounds).
Container Residue
Overlooking container residue. Container residue
must not be disregarded in release and other waste
management calculations. Even a "RCRA empty"
drum is expected to contain a residue and it must be
considered for TRI reporting. Additionally, on-site
drum rinsing and disposal of the rinsate will result in
a release and other waste management activity. Refer
to Estimating Releases and Waste Treatment
Efficiencies for Toxic Chemical Reporting Forms.
Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
Part I. Facility Identification Information
Section 1. Reporting Year
• Invalid Forms. The correct version of the form for
the reporting year in question must be used. For
example, forms provided for reporting years
1987-1990 must not be used to report data for
reporting years 1991-1995. Form Rs provided for
reporting years 1991-1995 mustnotbe used to report
data for years 1996 and later
Section 2. Trade Secret Information
- Incomplete off-site and POTW information
(e.g., missing city name)
If amounts are reported in units other than pounds (e.g., metric
units) or with exponential numbers, EPA may require a
revision of the Form R/Form A submitted. The exception is
for the reporting of dioxin and dioxin-like compounds where
the amounts are reported in grams.
• Incorrect completion of trade secret information.
The responses to trade secret questions in Part I
Section 2 and Part II Section 1.3 of FormR/Form A
must be consistent. If trade secrecy is indicated, a
sanitized Form R/Form A and two trade secret
substantiations (one sanitized) must be submitted in
the same package as the unsanitized trade secret
Form R/Form A. Part II Section 1.3 should be blank
if no trade secret claim is being made. Also, if you
indicate in Part I, Section 2.1 that you are not
claiming trade secret information, leave Part I, 2.2
blank.
Section 3. Certification
• Missing certification signature. If you are
submitting your Form R and/or Form A by hardcopy,
an original certification signature must appear on
page 1 of every Form R and/or Form A submitted to
EPA. If you are submitting your Form R and/or
Form A via TRI-MEweb and CDX, you must
electronically sign the submission before it can be
loaded into the TRI database, Uncertified electronic
submissions will not be accepted and result in a
Notice of Significant Error (NOSE) if they remain
uncertified after the July 1st reporting deadline.
Section 4. Facility Identification
• Questionable entries. Incorrect entries may require
corrections to be made by the facility. The use of the
TRI-MEweb software prevents most errors from
occurring. Questionable entries may include:
Missing or incorrect street address;
Missing or incorrect ZIP codes;
Missing County names;
Invalid SIC codes;
Missing or invalid Dun & Bradstreet
numbers;
- Missing or invalid RCRA, NPDES, or UIC
numbers; and
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Part II. Chemical-Specific Information
Section 1. Toxic Chemical Identity
• Reporting chemical abstract service (CAS)
registry numbers in Section 1.1. Beginning with
the 1991 reporting year, EPA has assigned
alphanumeric category codes to the twenty chemical
categories for the purposes of reporting the CAS
number field in Section 1.1. When completing a
Form R for a chemical category, the appropriate code
for that category must be provided in Section 1.1.
The CAS numbers are listed in Table II: "Section 313
Toxic Chemical List," and if needed, the category
codes are listed in Appendix B: "Reporting Codes for
EPA Form R." Category guidance documents are
listed in the Chemical and Industry Guidance
Documents section in this document.
• Failure to check for synonyms. Some reportable
chemicals (especially glycol ethers and toluene
diisocyanates) have many synonyms that do not
readily imply they are in the category. For example,
benzene,!,3-diisocyanatomethyl may not be readily
recognized as toluene diisocyanate (mixed isomers).
• Invalid chemical identification in Section 1.2. The
CAS number and the chemical name reported here
must exactly match the listed official EPCRA section
313 CAS number and EPCRA section 313 chemical
name.
• Failure to consider an EPCRA section 313
chemical qualifier. Only EPCRA section 313
chemicals in the form specified in the qualifier
require reporting under section 313 and should be
reported on Form R with the appropriate qualifier in
parentheses. For example, isopropyl alcohol is listed
on the EPCRA section 313 chemical list with the
qualifier manufacturing- strong acid process, no
supplier notification. Thus, the ONLY facilities that
should report this EPCRA section 313 chemical are
those that manufacture isopropyl alcohol by the
strong acid process.
• Generic chemical name in Section 1.3. A generic
chemical name should only be provided if the section
313 chemical identity is claimed as a trade secret.
Section 2. Mixture Component Identity
• Identifying chemicals used in mixtures. Facilities
should carefully review the most recent MSDS or
supplier notification for every mixture brought on-
site to identify all section 313 chemicals used during
a reporting year. Although some mixtures may not
have MSDSs, the best readily available information
should be used to determine the presence of EPCRA
section 313 chemicals in ores and alloys.
• Mixture names in Section 2.1. Mixture names are to
be entered here only if the supplier is claiming the
identity of the EPCRA section 313 chemical a trade
secret and that is the sole identification. Mixture
names that include the name or CAS number of one
or more EPCRA section 313 chemicals are not valid
uses of the mixture name field.
Section 3. Activities and Uses of the Toxic
Chemical at the Facility
• Reporting EPCRA section 313 chemical activity.
EPCRA section 313 chemical activity is commonly
overlooked or misclassified. Any activity involving
the manufacture, process, or otherwise use of an
EPCRA section 313 chemical must be examined. For
example, waste treatment operations otherwise use
EPCRA section 313 chemicals to treat waste streams
and may coincidentally manufacture an additional
EPCRA section 313 chemical as a result of the
treatment reaction. Such activity must be considered.
Further, EPCRA section 313 chemical activity must
be correctly classified as either "manufactured,"
"processed," or "otherwise used."
• Section 3.1 Manufacture means to produce, prepare,
compound, or import an EPCRA section 313
chemical.
• Section 3.2 Process means the preparation of
an EPCRA section 313 chemical after its
manufacture, which usually includes the
incorporation of the EPCRA section 313 chemical
into the final product, for distribution in commerce.
• Section 3.3 Otherwise use encompasses any use
of an EPCRA section 313 chemical that does not fall
under the terms "manufacture" or "process," and
includes treatment for destruction, stabilization
(without subsequent distribution in commerce),
disposal, and other use of an EPCRA section 313
chemical, including an EPCRA section 313 chemical
contained in a mixture or other trade name product.
Otherwise use of an EPCRA section 313 chemical
does not include disposal, stabilization (without
subsequent distribution in commerce), or treatment
for destruction unless:
1. The EPCRA section 313 chemical that was
disposed, stabilized, or treated for destruction
was received from off-site for the purposes of
further waste management; or
2. The EPCRA section 313 chemical that was
disposed, stabilized, or treated for destruction
was manufactured as a result of waste
management activities on materials received
from off-site for the purposes of further waste
management activities.
Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
For example, solvents in paint applied to a manufactured
product are often misclassified as processed, instead of
otherwise used. Because the solvents are not incorporated into
the final product, the solvent is being otherwise used, not
processed.
Section 4. Maximum Amount of the Toxic
Chemical On-site at Any Time During the
Calendar Year
• Maximum amount on-site left blank Failure to
provide the appropriate code for maximum amount
on site.
Section 5. Quantity of the Toxic Chemical
Entering Each Environmental Medium On-site
• Incorrectly reporting stack emissions. Fugitive
emissions from general indoor air should not be
reported as stack missions when released from a
single building vent. Additionally, stack emissions
from storage tanks, including loading, working, and
breathing losses from tanks, should not be
overlooked or reported as fugitive emissions.
• Overlooking releases to land. Section 313
chemicals placed in stockpiles or in surface
impoundments should be reported as a "release to
land" even if no section 313 chemicals leak from
these sources. Quantities of section 313 chemicals
land-treated should be reported as a release to land.
Section 6. Transfers of the Toxic Chemical in
Wastes to Off-site Locations
• Reporting discharges to POTWs in Section 6.1.
When quantities of a listed mineral acid are
neutralized to a pH of 6 or greater, the quantity
reported as discharged to a POTW should be
reported as zero. It is incorrect to enter "NA" (Not
Applicable), in such a situation.
• Reporting other off-site transfers in Section 6.2.
Any quantities reported in Sections 8.1, 8.3, 8.5, and
8.7 as sent off-site for disposal, treatment, energy
recovery, or recycling, respectively, must also be
reported in Section 6.2 along with the receiving
location and appropriate off-site activity code.
Section 7A. On-Site Waste Treatment
Methods and Efficiency
• Failure to report waste treatment methods in
Section 7A. Waste treatment methods used to treat
waste streams containing EPCRA section 313
chemicals, and the efficiencies of these methods,
must be reported on Form R. Information must be
entered for all waste streams, even if the waste
treatment method does not affect the EPCRA section
313 chemical. If no waste treatment is performed on
waste streams containing the EPCRA section 313
chemical, the box marked Not Applicable in Section
7A should be checked on Form R.
• Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, waste
treatment efficiency, and waste treatment method for
each waste stream are required to be reported on
Form R using specific codes. The waste treatment
codes are listed in Appendix B: Reporting Codes for
EPA Form R. A table is also provided in Appendix
B that displays a crosswalk between the old codes
and new ones for reporting year 2005.
Section 7B. On-Site Energy Recovery
Processes
• Reporting on-site energy recovery methods in
Section 7B. When a quantity is reported in Section
8.2 as combusted for energy recovery on-site, the
type of energy recovery system used must be reported
in Section 7B, and vice versa.
Section 7C. On-Site Recycling Processes
• Reporting on-site recycling methods in Section
7C. When a quantity is reported in Section 8.4 as
recycled on-site, the type of recovery method must be
reported in Section 7C, and vice versa.
Section 8. Source Reduction and Recycling
Activities
The TRI-MEweb software offers a Section 8 Calculator. The
Section 8 Calculator will assist users in calculating their
Section 8 source reduction and recycling activity quantities.
Please note that if you use range codes to report data in
sections 5 and 6, TRI-MEweb will default to the mid-point of
the range when performing section 8 calculations.
The entries in this section must be completed, even if your
facility does not engage in source reduction or recycling
activities.
• Columns C and D, the future year projections for
questions 8.1 through 8.7, must be completed. EPA
expects a reasonable estimate for the future year
projections. Zero can be used in columns C and D to
indicate that the manufacture, process, or otherwise
use of the chemical will be discontinued. In such
cases, columns C and D for Section 8.1 through 8.7
must all contain zeroes.
• It is incorrect to use range codes to report quantities
in Section 8. Range codes can be used only in
Sections 5 and 6 of Form R.
• It is incorrect to use the same codes from Section 4
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Appendix C
for reporting the maximum amount of the reported
EPCRA section 313 chemical on-site to report
quantities in Section 8.
• Quantities reported in Section 8.1 through 8.7 are
mutually exclusive and additive. This means that
quantities of the reported EPCRA section 313
chemical must not be double-counted in Section 8.1
through 8.7.
• Some double-counting errors have been due to
confusion over the differences in how on-site
treatment of an EPCRA section 313 chemical is
reported in Section 7 A as compared to Section 8. In
Section 7A, information on the treatment of waste
streams containing the EPCRA section 313 chemical
is reported, along with the percent efficiency in terms
of destruction or removal of the EPCRA section 313
chemical from each waste stream. In Section 8, only
the quantity of the EPCRA section 313 chemical
actually destroyed through the treatment processes
reported in Section 7A is reported in Section 8.6 to
avoid double-counting within Sections 8.1 through
8.7.
• Quantities reported in Section 8.1 through 8.7 must
not be reported in Section 8.8 and vice versa.
• Any time a reported EPCRA section 313 chemical is
contained in a waste, and the waste is associated with
routine production-related activities and is recycled,
combusted for energy recovery, treated, disposed, or
otherwise released either on- or off-site, that quantity
of the EPCRA section 313 chemical must be included
in the quantities reported in Sections 8.1 through 8.7
• Reporting quantities in Section 8.1 Quantities of
EPCRA section 313 chemicals that are released
(including disposed) on-site and reported in Section 5
of Form R must be reported in either Section 8. la or
8.1b.
§8.1a= § 5.4.1 + § 5.5.1A+ § 5.5.IB - § 8.8 (on-site
release or disposal due to catastrophic events)1
§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + §
5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site release or
disposal due to catastrophic events)1
Quantities of EPCRA section 313 chemicals
transferred off-site for the purposes of disposal
reported in Section 6.2 using the following codes
must appear in Section 8. Ic:
- M64 Other Landfills
- M65 RCRA Subtitle C Landfills
M81 Underground Injection to Class I Wells
§ 8.1c = § 6.1 (portion of transfer that is untreated
and ultimately disposed of in UIC Class I Wells,
RCRA Subtitle C landfills, and other landfills) + §
6.2 (quantities associated with M codes M64, M65
and M81) - § 8.8 (off-site disposal due to
catastrophic events)1
Metals and metal category compounds transferred
off-site to POTWs in Section 6.1 must appear in
Section 8. Ic or 8. Id. To report correctly in Sections
8. la through d, a facility must include quantities that
are disposed or otherwise released to the environment
either on-site or off-site, excluding disposal or other
releases due to catastrophic events or non-production
related activities.
Quantities of EPCRA section 313 chemicals
transferred off-site for the purposes of disposal
reported in Section 6.2 using the following codes
must appear in Section 8. Id:
- M10 Storage Only
M41 Solidification/Stabilization - Metals and
Metal Category Compounds Only
M62 Wastewater Treatment (excluding
POTW) - Metals and Metal Category
Compounds Only
M66 Subtitle C Surface Impoundment
M67 Other Surface Impoundments
- M73 Land Treatment
- M79 Other Land Disposal
M82 Underground Injection to Class II-V
Wells
- M90 Other Off-Site Management
- M94 Transfer to Waste BrokerCDisposal
- M99 Unknown.
§8.1d = §6.1 (portion of transfer that is untreated
and ultimately disposed of in UIC Class II-V wells,
and disposal other than to landfills) + § 6.2
(quantities associated withM codes M10, M41, M62,
M66, M67, M73, M79, M82, M90, M94, M99) - §
8.8 (off-site disposal due to catastrophic events)1
• Reporting quantities in Section 8.2 "Quantity
used for energy recovery on-site." A quantity must
be reported in Section 8.2 for the current (reporting)
year when a method of on-site energy recovery is
reported in Section 7B, and vice versa. An error
facilities make when completing Form R is to report
the methods of energy recovery used on-site in
Section 7B but not report the total quantity associated
with those methods. Another error is to report a
quantity in this section if the combustion of the
EPCRA section 313 chemical took place in a system
that did not recover energy (e.g., an incinerator). A
quantity of the EPCRA section 313 chemical
1 §8.8 includes quantities of toxic chemicals disposed or otherwise released
on site or managed as a waste off site due to remedial actions, catastrophic
events, or one-time events not associated with the production processes.
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Appendix C
combusted for energy recovery must not be reported
if the EPCRA section 313 chemical does not have a
significant heating value. Examples of EPCRA
section 313 chemicals that do not have significant
heating values include metals, metal portions of metal
category compounds, and halons. Metals and metal
portions of metal compounds will never be treated or
combusted for energy recovery. Any quantities of the
EPCRA section 313 chemical associated with
non-production related activities such as catastrophic
releases and remedial actions, as well as other
one-time events not associated with routine
production practices that were combusted for energy
recovery on-site must not be included in Section 8.8.
• Reporting quantities in Section 8.3 "Quantity used
for energy recovery off-site." As in Section 8.2, a
quantity must not be reported in this section if the
off-site combustion of the EPCRA section 313
chemical took place in a system that did not recover
energy (e.g., incinerator). A quantity of an EPCRA
section 313 chemical must not be reported as sent
off-site for the purposes of energy recovery if the
EPCRA section 313 chemical does not have a
significant heating value. Examples of EPCRA
section 313 chemicals that do not have significant
heating values include metals, metal portions of metal
category compounds, and halons. Metals and metal
portions of metal category compounds will never be
combusted for energy recovery. Quantities must be
reported in Section 8.3 that are reported in Section
6.2 as transferred off-site for the purposes of
combustion for energy recovery using the following
codes:
M56 Energy Recovery
- M92 Transfer to Waste Broker C Energy
Recovery
§ 8.3 = § 6.2 (energy recovery) - § 8.8 (off-site
energy recovery due to catastrophic events)2
• Reporting quantities in Section 8.4 "Quantity
recycled on-site." A quantity must be reported in
Section 8.4 for the current reporting year when a
method of on-site recycling is reported in Section 7C,
and vice versa. An error facilities make when
completing Form R is to report the methods of
recycling used on-site in Section 7C but not report
the total quantity recovered using those methods.
In addition, only the amount of the chemical that was
actually recovered is to be reported in Section 8.4.
Any quantities of the EPCRA section 313 chemical
associated with non-production related activities such
as catastrophic releases and remedial actions, as well
§8.8 includes quantities of toxic chemical disposed or otherwise released
on-site or managed as waste off-site due to remedial actions, catastrophic
events, or one-time events not associated with the production processes.
as other one-time events not associated with routine
production practices that were recycled on-site must
not be included in Section 8.8.
• Reporting quantities in Section 8.5. "Quantity
recycled off-site." Quantities reported in Section 6.2
as transferred off-site for the purposes of recycling
must be included in Section 8.5 using the following
codes:
M20 Solvents/Organic Recovery
- M24 Metals Recovery
- M26 Other Reuse or Recovery
- M28 Acid Regeneration
- M93 Transfer to Waste Broker C Recycling.
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling due
to catastrophic events)2
• Reporting quantities in Section 8.6 "Quantity
treated on-site." Quantities may not always have to
be reported in Section 8.6 when Section 7A is
completed. This is because the information reported
in Section 7 A and Section 8 is different. Information
on how waste streams containing the reported
EPCRA section 313 chemical are treated is reported
in Section 7A, while the quantity of the EPCRA
section 313 chemical actually destroyed as a result of
on-site treatment is reported in Section 8.6. If a
quantity is reported in Section 8.6, Section 7A must
be completed but the reverse may not be true. This
may result in apparent discrepancies between Section
7A and Section 8. For example, a facility may treat
wastewater containing an EPCRA section 313
chemical by removing the EPCRA section 313
chemical and then disposing of it on-site. The
treatment of the wastewater would be reported in
Section 7 A, with an efficiency estimate based on the
amount of the EPCRA section 313 chemical removed
from the wastewater. Although the waste stream has
been treated because the EPCRA section 313
chemical has been removed, the EPCRA section 313
chemical has not been treated because it has not been
destroyed. The facility would report only the amount
of the EPCRA section 313 chemical actually
destroyed during treatment in Section 8.6 and the
amount ultimately disposed in Section 8.1 to avoid
double-counting the same quantity in Section 8. In
cases where the EPCRA section 313 chemical is not
destroyed during a treatment process and
subsequently enters another activity, such as disposal
(e.g., metals removed from wastewater and
subsequently disposed on-site), the quantity of the
EPCRA section 313 chemical would be reported as
disposed in Section 8.1, not as treated in Section 8.6.
Any quantities of the EPCRA section 313 chemical
associated with non-production related activities such
as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine
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Appendix C
production practices that were treated for destruction
on-site must not be included in Section 8.8. Metals
generally will not be treated for destruction.
• Reporting quantities in Section 8.7 "Quantity
treated off-site." Quantities reported in Section 6.2
as transferred off-site for the purposes of treatment
must be included in Section 8.7 using the following
codes:
- M40 Solidification/Stabilization
- M50 Incineration/Thermal Treatment
- M54 Incineration/Insignificant Fuel Value
M61 Wastewater Treatment (excluding
POTW)
- M69 Other Waste Treatment
- M95 Transfer to Waste Broker C Waste
treatment.
Quantities of an EPCRA section 313 chemical,
except metals and metal category compounds, sent
off-site to a POTW should also be reported in Section
8.7. If you know, however, that a chemical is not
treated for destruction at the POTW you should
report that quantity in Section 8.1 instead of 8.7.
To report correctly EPCRA section 313 chemicals in
Section 8.7, use the following equation.
§8.7 =§6.1 (excluding most metal/metal category
compounds) + §6.2 (treatment) - §8.8 (off-site
treatment due to catastrophic events)3
• Reporting quantities in Section 8.8 Quantity
released to the environment as a result of
remedial actions, catastrophic events or one-time
events not associated with production processes.
The quantities that are reported in Section 8.8 are
associated with non-production related activities such
as catastrophic releases and remedial actions, as well
as one-time events not associated with routine
production practices, that were disposed or released
directly to the environment or transferred off-site for
the purposes of recycling, energy recovery, treatment
or disposal. Quantities reported in Section 8.8 must
not be reported in Section 8.1 through 8.7.
• Reporting the production ratio in Section 8.9. A
production ratio or activity index must be provided in
Section 8.9. A zero is not acceptable and NA (Not
Applicable) can be used only when the reported
EPCRA section 313 chemical was not manufactured,
processed, or otherwise used in the year prior to the
reporting year.
• Calculating production ratio in Section 8.9. In
3§8.8 includes quantities of toxic chemical disposed or otherwise released
on-site or managed as waste off-site due to remedial actions, catastrophic
events, or one-time events not associated with the production processes.
calculating a production ratio for otherwise used
chemicals, an activity index must be used rather than
quantities purchased or released from year to year.
• Reporting source reduction activities in Section
8.10. It is an error to report a source reduction
activity in Section 8.10 and not report at least one
method used to identify that activity and vice versa.
C.4 FDP Messages Used to
Report Notices of
Significant Errors
Note: EPA is continually trying to improve the error
checking system for TRI submissions. As a result, a
small number of the error messages in this appendix
may be changed by the time the Reporting Year 2009
submissions are checked. Most of these messages
will remain the same. You can look for changes to
these error messages on the TRI home page at
http://www.epa.gov/tri
1. You have used an invalid Form R or Form A by using
either a form not applicable for the reporting year, or
a facsimile form that has not been approved by EPA.
Resubmit your data on a current EPA approved Form
RorA.
2. Pages were missing from the form received. Correct
this by resubmitting a complete certified form for this
chemical substance.
3. Multiple chemicals were reported in your Form R.
You must submit a separate and complete Form R for
each chemical cited.
4. You have provided a valid CAS number and a valid
chemical name, but they do not match. Respond by
providing a valid CAS number and matching
chemical name.
5. You have left part or all of the chemical identification
sections blank. Respond by providing a valid CAS
number and matching chemical name or Mixture
Component Identity.
6. You reported a CAS number and chemical name that
are invalid. Respond by providing a valid CAS
number and matching chemical name.
7. Your form indicated Trade Secret status with an
indication that this form is a Sanitized version, but
the report contains no Generic Chemical Name. You
must provide a Generic Chemical Name for this
sanitized form.
8. You did not sign the Form Per EPCRA Section
313(g)(l)(B), each submission must contain an
original signature certifying the accuracy and
completeness of the information reported by signing
the certification statement on the Form or certified
Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
letter. Please be sure to sign the certification
statement in this FDP to certify your submission data.
9. You have reported Dioxin and Dioxin-like
Compounds on a Form A. Dioxin and Dioxin-like
Compounds are not eligible for the alternate
threshold. Thus, this chemical must be reported on a
Form R. Please resubmit your data on a Form R.
10. In Part I, Section lof the Form R or Form A
Certification Statement You did not enter a reporting
year. (Note: EPA has set the year to 2084 as a
default.) You must enter a valid reporting year for
your Form R or Form A Certification Statement.
This entry cannot be left blank and NA may not be
used. (NOSE)
11. In Part I, Section lof the Form R or Form A
Certification Statement you provided an invalid or
future reporting year. You must enter a valid
reporting year for your Form R or Form A
Certification Statement. Valid years are 1987 through
2002. This entry cannot be left blank and NA may
not be used. (NOSE)
12. You have reported a negative number(s) in Part II,
Sections 5 and/or 6 and/or 8 of your Form R.
Quantities reported in these sections must be 0 or
greater. Please respond by providing correct release
or other waste management data.
13. You did not complete Part II, Sections 5 and 6.
Please provide the required information; otherwise
indicate NA.
14. You did not complete Part II, Section 7. Please
provide the required information; otherwise indicate
NA.
15. You did not complete Part II, Section 8. Please
provide the required information; otherwise indicate
NA.
C.5 Messages Used to
Report Notices of Technical
Errors (NOTEs) and Non-
technical Data Changes
(NDCs)
Invalid codes throughout Form R
16. You submitted an invalid code. To correct this,
consult the instructions for the proper table value and
provide a valid code value. [Specific location on the
form of the invalid code is given.] (NOTE)
17. PBT chemicals (e.g., Dioxin and Dioxin-like
Compounds, Lead Compounds, Mercury Compounds
and Polycyclic Aromatic Compounds (PACs)) are
ineligible for range reporting for on-site releases and
transfers off-site for further waste management.
Please provide specific release, transfer, and other
waste management values. (NOTE)
18. For aluminum (fume or dust) or zinc (fume or dust),
the Waste Management codes M56 and M92 are
unacceptable. Please provide the proper Waste
Management codes for these chemicals. (NOTE)
19. For asbestos (friable), the Waste Management codes
M56 and M92 are unacceptable. Please provide the
proper Waste Management codes for these chemicals.
(NOTE)
General Errors for both the Form R and/or
Form A
20. You reported a negative value for a release, transfer
or other waste management quantity. Please provide
a non-negative value for the specified part and
section. (NOTE)
21. You have reported a value for a PBT chemical
beyond seven digits to the right of the decimal.
EPA's data management systems support data
precision up to seven digits to the right of the
decimal. EPA has truncated your numeric
submission so the number of digits to the right of the
decimal do not exceed seven. If this was incorrect,
specify the correct value, not exceeding seven digits
to the right of the decimal. (NDC)
Errors in Part I, Facility Identification
Information
22. No selection was made in Part I, Section 2.1 and 2.2
(Trade Secret Information) and a generic chemical
name was not provided in Part II, Section 1.3.
Therefore, the No box was selected in Part I, Section
2.1. If this was incorrect, and you intended to make a
trade secret claim of the identity of the toxic
chemical, you must resubmit following the
requirements of 40 CFR Part 350 to claim trade
secret. (NDC)
23. You indicated trade secret in Part I, Section 2.1
(Trade Secret Information) but made no selection for
Part I, Section 2.2 (sanitized/unsanitized) and did not
provide a generic chemical name in Part II, Section
1.3. EPA changed your selection in Part I, Section
2.1 to indicate that a trade secret claim is not being
made. If this was incorrect, and you intended to
make a trade secret claim for the identity of the toxic
chemical, you must resubmit following the
requirements of 40 CFR Part 350 to claim trade
secret. (NDC)
24. You made a selection of No in Part 1, Section 2.1
(Trade Secret Information) and selected unsanitized
in Part 1, Section 2.2. In Part II, Section 1.3 a
generic name was indicated. Part II, Section 1.3
C-10
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Appendix C
should be completed only if trade secret is being
claimed (Part 1, Section 2.1). EPA will move the
chemical name information in Part II, Section 1.3 to
Part II, Section 1.2. If this is incorrect and you wish
to claim trade secret, you must resubmit following the
requirements of 40 CFR Part 350. (NDC)
25. In Part I, Section 4.1, you entered NA or did not
enter a county name, city name, state code, and/or zip
code. These fields may not be left blank and NA is
not an acceptable entry. You must provide a county
name, city name, state code, and/or zip code where
the facility is located. (NDC)
26. EPA has corrected the county name, city name, state
code, and/ or zip code that you identified in Part I,
Section 4.1. The county name, city name, state code,
and/ or zip code that you identified was either mis-
spelled, or incorrect, or did not match the previous
year submissions. If you feel our correction was
made in error, please resubmit forms with correct
information. (NDC)
27. In Part I, Section 4.1, you have used an invalid
TRIFID or you have self-assigned your own TRIFID
or TRIFID that has been superceded. You may not
generate your own TRIFID. The TRI Data Processing
Center assigns this number to a facility. EPA has
corrected this error and assigned you the correct
TRIFID. Please note the corrected TRIFID and keep
it for use in future submissions. (NDC)
28. No Public Contact name and/or telephone number
was listed. Please provide the name and telephone
number of your Public Contact. (NOTE)
29. No Technical Contact name and/or telephone number
was listed. Please provide the name and telephone
number of your Technical Contact. (NOTE)
30. The Federal Facility box was not checked on your
form but we believe you are a Federal Facility.
Unless you respond that you are not a Federal
Facility, we will continue to treat you as a Federal
Facility. (NOTE)
31. A valid NAICS code was not provided. Please
provide at least one valid primary six-digit NAICS
code. (NOTE)
32. You reported an invalid state code. If the address is
in the US, please use a valid US Postal Service state
code (see Table III of the Reporting Forms and
Instructions). If the address is not in the US, please
enter a valid code in the Country Field (see Table IV
of the Reporting Forms and Instructions) (NOTE)
3 3. Either Box A (An Entire Facility) or Box B (Part of a
Facility) should be checked in Part I, Section 4.2.
One of the 2 boxes must be checked, but not both.
(NOTE)
If applicable, check either Box C (Federal Facility) or
Box D (GOCO) in Part I, Section 4.2, but do not
check both boxes. (NOTE)
You did not enter Longitude or Latitude values for
the facility. Please enter a Longitude and Latitude
value. (NOTE)
36. You entered an invalid Longitude/Latitude value(s).
Longitude degrees must be between 0 and 180,
latitude degrees must be between 0 and 90; minutes
and seconds for either latitude or longitude must be
between 0 and 60. (NOTE)
37. Dun and Bradstreet Numbers (Part I Section 4.7) are
typically 9 characters in length. Please check the
number(s) submitted. If they are incorrect, please
make the appropriate changes. If you believe that
they are correct, no further action is necessary.
(NOTE)
38. EPA Identification Numbers (RCRA I.D. No. Part I
Section 4.8) are typically 12 characters in length.
Please check the number(s) submitted. If they are
incorrect, please make the appropriate changes. If
you believe that they are correct, no further action is
necessary. (NOTE)
39. NPDES Permit Numbers (Part I, Section 4.9) are
typically 9 characters in length. Please check the
number(s) submitted. If they are incorrect, please
make the appropriate changes. If you believe that
they are correct, no further action is necessary.
(NOTE)
40. Underground Injection Well Code (UIC) I.D.
Numbers (Part I, Section 4. 10) are typically 12 digits.
Please check the number(s) you have supplied. If they
are incorrect, please make appropriate changes. If
you believe that they are correct, no further action is
necessary. (NOTE)
41. If this is a North American phone number, please
enter all 10 digits (i.e., include area code). If this is
for another country, please begin the phone number
with "Oil" as the prefix to your international
telephone number. (NOTE)
42. In Part I, Section 3, you did not provide a printed or
typed name and official title of owner/operator or
senior management official. It cannot be N/A or left
blank. Please provide a name for owner/operator or
senior management official. (NOTE)
43. In Part I, Section 5.1 you did not enter the name of
the parent company. This block cannot be left blank.
You must enter the name for the parent company if it
is a U. S. company. If it is a foreign company then you
may check the [NA] box. (NOTE)
44. The parent company Dun and Bradstreet Number in
Part I, Section 5.2 (typically a 9-digit number )
cannot be left blank. However, if your parent
Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
company does not have a Dun and Bradstreet
Number check the [NA] box next to Part I, Section
5.2. (NOTE)
Errors in Part II, Section 1. Toxic Chemical
Identity
45. You have correctly identified the chemical but have
used a synonym for the chemical name. EPA has
changed the Chemical Name to use the preferred TPJ
nomenclature. Please specify the correct CAS
Number and matching Chemical Name. (NDC)
46. The CAS number you reported was changed to match the
chemical name reported, because the CAS number
you provided was not a valid TRI Chemical. If this
was incorrect, specify a valid CAS number and
matching chemical name. (NDC)
47. The chemical name you reported was changed to
match the CAS number reported, because the
chemical name you provided was not a valid TRI
Chemical. If this was incorrect, specify a valid CAS
Number and matching Chemical Name. (NDC)
48. You reported a valid TRI CAS Number, a valid
Chemical Name, and a generic Chemical Name.
Therefore, the Generic Chemical Name was deleted.
If this was incorrect, specify the Generic Chemical
Name to be used. (NDC)
49. You reported a valid TRI CAS Number, a valid
Chemical Name, and a Mixture Component Identity.
Therefore, the Mixture Component Identity was
deleted. If this was incorrect, specify the Mixture
Component Identity to be used. (NDC)
50. EPA has changed the TRI chemical category code
you reported in Part II, Section 1.1 from N151 to
N150 (the code was incorrectly listed in some pages
of the Reporting Forms and Instructions), the correct
TRI chemical category code for Dioxin and Dioxin-
like Compounds. If this is incorrect and you are not
reporting Dioxin and Dioxin-like Compounds, please
specify the correct CAS number or chemical category
code and matching chemical name.(NDC)
51. You have reported for isopropyl alcohol (Only
persons who manufacture by the strong acid process
are subject) (CAS number 67-63-0). If you did not
manufacture isopropyl alcohol by the strong acid
process, you have submitted this form in error and
should request that the form be withdrawn. (NOTE)
Errors in Form R, Part II, Section 1.4. Dioxin
and Dioxin-like Compounds
52. EPA has deleted the entry of zeros in Part II, Section
1.4 because you indicated a CAS number or chemical
category in Part II, Section 1.1 other than Dioxin and
Dioxin-like Compounds. When reporting for a
chemical other than Dioxin and Dioxin-like
Compounds, you should leave Section 1.4 blank.
(NDC)
53. You did not complete Section 1.4. If you report
Dioxin and Dioxin-like Compounds in Part II,
Sections 1.1 or 1.2, you must complete Section 1.4.
Please report the distribution of chemicals included
for Dioxin and Dioxin-like Compounds. If you do
not have speciation data available, indicate NA.
(NOTE)
54. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you
have indicated a CAS number or chemical category
code in Part II, Section 1.1 other than Dioxin and
Dioxin-like Compounds (N150). If you are reporting
for Dioxin and Dioxin-like Compounds, please
provide the proper chemical category code (N150).
Otherwise please indicate on the FDP that Section 1.4
should be left blank. (NOTE)
55. You did not provide values in all 17 boxes in Part II,
Section 1.4 and/or the values do not total to 100%.
When reporting the distribution of each member of
the Dioxin and Dioxin-like Compounds category, you
must fill in each of the 17 boxes in Part II, Section
1.4 witheitherO or a number between 0.01 and 100.
The summation of the 17 fields in Section 1.4 must
equal 100. Please review Part II, Section 1.4 and
enter values where needed and/or adjust the
percentages where needed so that their summation
equals 100%. (NOTE)
56. You reported numeric values in Part II, Section 1.4
for a chemical that is not Dioxin and Dioxin-like
Compounds. It appears that the information reported
in Part II, Section 1.4 is not valid. If you are
reporting for Dioxin and Dioxin-like Compounds,
please indicate on this FDP that the chemical
category name in Part II, Section 1.2 should be
Dioxin and Dioxin-like Compounds, or submit a new
Form R. Otherwise, please indicate on this FDP that
the values in Part II, Section 1.4 should be blank.
(NOTE)
57. Part II, Section 1.4 of your Form R contains data for
Dioxin and Dioxin-like Compounds. However, you
have indicated both NA and a numeric value (which
includes zero). When reporting the distribution of
each member of the Dioxin and Dioxin-like
Compounds category, you must fill in each of the 17
boxes in Part II, Section 1.4 with either 0 or a number
between 0.01 and 100. The summation of the 17
fields in Section 1.4 must equal 100. If you do not
have speciation data available, indicate NA rather
than zero. (NOTE)
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Appendix C
Errors in Part II, Section 3. Activities and Uses
of Toxic Chemical At The Facility
58. You did not indicate in Part II, Section 3 which
activity(ies) or use(s) of the EPCRA section 313
chemical occur at your facility. Please indicate at
least one of the activity(ies) and use(s) of the EPCRA
section 313 chemical occur at your facility. (NOTE)
Errors in Part II, Section 4. Maximum Amount
of the Toxic Chemical Onsite At Any Time
During the Calendar Year
59. You did not complete Part II, Section 4.1. Please
provide a valid two digit code for the "maximum
amount of chemical on-site at any time during the
calendar year." (NOTE)
Errors in Part II, Section 5. Quantity of the
Toxic Chemical Entering Each Environmental
Medium Onsite
60. You did not complete Part II, Section 5.3. If you have
discharged to water, please provide the Stream/Water
Body name, the Release estimate or range code,
Basis of Estimate and %from Stormwater; otherwise
indicate "NA" (Not Applicable). (NOTE)
61. There are missing or incomplete data for Part II,
Section 5.3. If you have discharged to water, please
provide the Stream/Water Body name, the Release
estimate or range code, Basis of Estimate and %from
Stormwater; otherwise indicate "NA" (Not
Applicable). (NOTE)
62. You did not complete Part II, Section 5. Please
provide the Release estimate or range code and Basis
of Estimate; otherwise indicate "NA" (Not
Applicable). (NOTE)
63. There are missing or incomplete data for Part II,
Section 5. Please provide the Release estimate or
range code and Basis of Estimate; otherwise indicate
"NA" (Not Applicable). (NOTE)
Errors in Part II, Section 6. Transfers of the
Toxic Chemical In Wastes To Off-Site
Locations
64. You did not complete Part II, Section 6.1,
"discharges to POTW." If you did not discharge
wastewater containing the section 313 chemical to a
POTW(s), enter "NA" (Not Applicable), otherwise
please provide the Transfer amount or range code,
Basis of Estimate, POTW Name and Location.
(NOTE)
65. You reported a POTW(s) name and location but did
not provide a Transfer amount. Please provide a
Total Transfer amount or range code and Basis of
Estimate; otherwise, if there was no transfer to a
POTW of wastewater that contains or contained the
section 313 chemical, delete the POTW location and
indicate "NA" (Not Applicable) for the POTW
transfer amount. (NOTE)
66. You reported a Total Transfer amount or range code
and Basis of Estimate in Part II Section 6.1 but did
not indicate a POTW name and location in Section
6.1 .B. Please provide the POTW Name and Location.
(NOTE)
67. You provided an incomplete POTW name and
address. Please provide the name and complete
address for the POTW. (NOTE)
68. There are missing or incomplete data for Part II,
Section 6.1. Please provide the transfer amount or
range code and Basis of Estimate for Discharges to
POTWs. (NOTE)
69. You did not complete Part II, Section 6.2, "Transfers
to Other Off- site Locations." If you did not transfer
the waste containing the section 313 chemical to
other off-site locations, enter "NA" (Not Applicable),
otherwise please provide Offsite EPA ID, Name,
Location, Transfer amount or range code, Basis of
Estimate, and type of Waste Management code.
(NOTE)
70. You reported an Off-site Transfer amount or range
code and Basis of Estimate in Part II Section 6.2 but
did not indicate an Off-site name and location in
Section 6.2. Please provide the Off-site Name and
Location. (NOTE)
71. You reported an Off-site name and location but did
not provide a Transfer amount. Please provide a
Total Transfer amount or range code, Basis of
Estimate and type of Waste Management code;
otherwise, if there was no transfer to this Off-site
location, delete the Off-site name and location and
indicate "NA" (Not Applicable) in the Off-site EPA
Identification Number (RCRA ID No.) field.
(NOTE)
72. You provided both county and country data. If this is
an extra-national transfer, indicate the off-site name,
address, and Country Code; if a domestic Offsite,
provide the Off-site Name and correct address.
(NOTE)
73. You reported an Off-site name and location, but there
are missing or incomplete data for the off-site transfer
amount, basis of estimate and type of waste
management code. Please provide the Off-site
Transfer amount or range code, Basis of Estimate,
and type of Waste Management code. (NOTE)
74. You provided incomplete off-site name and address
data. For a transfer to a domestic off-site location,
you must provide a street address, city, state, county
and zip code. For a transfer to a foreign off-site
Toxics Release Inventory Reporting Forms and Instructions
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Appendix C
location, you must provide a street address, city and a
two character country code. (NOTE)
75. You reported an invalid Type of Waste Management
code. For metals/metal compounds use only disposal
and certain recycling activities codes. Consult the
Reporting Instructions for metal and metal
compounds and correct with a valid Waste
Management (i.e., "M") code. (NOTE)
76. You reported an invalid Type of Waste Management
code. For Barium Compounds use only disposal and
certain recycling activities codes, M61-Wastewater
Treatment (Excluding POTW) or M69-Other Waste
Treatment. Consult the Reporting Instructions for
metal and metal compounds and correct with a valid
Waste Management (i.e., "M") code. (NOTE)
77. For non-metals codes M41 and M62 are
unacceptable. Provide the appropriate Disposal or
Other Waste Management code for this non-metal
substance. (NOTE)
78. In Part II, Section 6.2 column C you reported M
codes (M56 and/or M92) for energy recovery,
however you left Section 8.3 column B blank. Please
provide the quantity used for energy recovery offsite
in pounds/year in Section 8.3 column B. (NOTE)
79. In Part II, Section 6.2 column C you reported M
Codes (M20, M24, M26, M28, M93) for recycling,
however you left Section 8.5 column B blank. Please
provide the quantity recycled offsite in pounds/year
in Section 8.5 column B. (NOTE)
80. In Part II, Section 6.2 column C you reported M
Codes (M40, M50, M54, M61, M69, M95) for
treatment, however you left Section 8.7 column B
blank. Please provide the quantity treated offsite in
pounds/year in Section 8.7 column B. (NOTE)
Errors in Part II, Section 7. On-Site Waste
Treatment Methods and Efficiency
81. There are no data contained in all of Part II, Section
7 A. If you do not treat wastes containing the EPCRA
section 313 chemical at your facility, indicate "NA;"
otherwise please provide the general waste stream
code, waste treatment methods, range of influent
concentration, waste treatment efficiency estimate
and whether this is based on operating data for all on-
site waste treatments for this chemical. (NOTE)
82. There are missing data in Part II, Section 7 A. Please
provide the general waste stream code, waste
treatment methods, range of influent concentration,
waste treatment efficiency estimate and whether this
is based on operating data. (NOTE)
83. There are no datainPartll, Section 7B. If no on-site
energy recovery processes are used for this section
313 chemical at your facility, indicate "NA;"
otherwise please provide at least one three-character
on-site energy recovery process code. (NOTE)
84. There are no datainPartll, Section 7C. If no on-site
recycling processes are used for this section 313
chemical at your facility, indicate "NA;" otherwise
please provide at least one three-character on-site
recycling process code. (NOTE)
Errors in Part II, Section 8. Source Reduction
and Recycling Activities
85. There are missing data for Part II, Section 8.1-8.7.
Please provide an estimate or"NA" (Not Applicable)
in each box for section 8.1 through 8.7, columns A,
B, C, and D. You may only use "NA" (Not
Applicable) when there is no possibility a release or
transfer occurred. You may enter zero if the release
or transfer was equal to or less than half a pound.
(NOTE)
86. There are missing data in Part II, Section 8.8. Please
provide an estimate or "NA" (Not Applicable). You
may only use "NA" (Not Applicable) when there is
no possibility a release or transfer occurred. You
may enter zero if the release or transfer was equal to
or less than half a pound. (NOTE)
87. There are no data in Part II, Section 8.9. Please
provide a production ratio, an activity index, or "NA"
(Not Applicable) if the chemical manufacture or use
began during the current reporting year. (NOTE)
88. There are no data in Part II, Section 8.10. If your
facility did not engage in any source reduction
activity for the reported chemical, enter "NA" (Not
Applicable) and answer 8.11. Otherwise please
provide Source Reduction Activities and Methods
code(s). (NOTE)
89. There are missing data in Part II, Section 8.10.
Please provide Source Reduction Activities and
Methods code(s). (NOTE)
90. Neither box was checked in section 8.11. Please
check one of the boxes in section 8.11 indicating if
additional information on source reduction, recycling,
or pollution control activities is included with your
Form R report. (NOTE)
91. You have reported a listed metal or metal compound
category in section 8.2, 8.3, 8.6 or 8.7. However,
these chemicals cannot be treated for destruction.
Metal or metal compound category can only be
reported as disposed or recycled. Please report
appropriately in Section 8.1, 8.4, or 8.5. (NOTE)
92. You reported a negative value for a release, transfer
or other waste management quantity. Please provide a
non-negative value for the specified part and section.
(NOTE)
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Appendix C
Errors relating to the reconciliation of data in
Part II, Section 8 and Part II, Sections 5, 6, and
7
93. You did not complete Sections 8.1 through 8.7
column B or 8.8. If you report releases in Part II,
Section 5 and/or an off-site transfer in Section 6.2
and/or quantities transferred off-site to POTWs in
Section 6.1, you must report an estimate in Part II,
Sections 8.1 through 8.7 column B and/or Section
8.8. (NOTE)
94. You did not complete Sections 5,6, or 7. If you enter
an estimate in Part II, Sections 8.1 through 8.7,
column B and/or Section 8.8, you must also report
releases in Part II, Section 5 and/or off-site transfers
in Section 6.2 and/or quantities transferred off-site to
POTWs in Section 6.1 and/or waste treatment, energy
recovery, or recycling codes in Section 7. Please
provide data for Sections 5, 6, and/or 7. (NOTE)
95. You reported an estimate in Part II, Section 8.2,
column B, "Quantity Used for Energy Recovery On-
site," but did not provide an on-site energy recovery
code in Part II, Section 7B. Please provide an on-site
energy recovery code for Part II, Section 7B.
(NOTE)
96. You reported an "On-site Energy Recovery Process"
code in Part II, Section 7B, but you did not provide
an estimate of the quantity used for energy recovery
in Part II, Section 8.2, column B. Please provide an
estimate of the quantity used for energy recovery for
Part II, Section 8.2, column B. (NOTE)
97. You reported an estimate in Part II, Section 8.4,
column B "Quantity Recycled On-site" but did not
provide an on-site recycling code in Part II, Section
1C. Please provide an on-site recycling code for Part
II, Section 7C. (NOTE)
98. You reported one or more on-site recycling process
codes in Part II, Section 7C but did not provide an
estimate in Part II, Section 8.4, column B, "Quantity
Recycled On-site." Please provide an estimate of the
quantity recycled for Section 8.4 column B. (NOTE)
99. You reported a value in Part II, Section 8.3 column
B, however you did not provide a corresponding
quantity with an appropriate M Code (M56
and/orM92) for energy recovery in Section 6.2
column C. Please provide the appropriate quantity
and M Codes for energy recovery in Section 6.2
column C. (NOTE)
100. You reported a value in Part II, Section 8.5 column
B, however you did not provide a corresponding
quantity with an appropriate M Code (M20, M24,
M26, M28, M93) for recycling in Section6.2 column
C. Please provide the appropriate quantity and M
Codes for recycling in Section 6.2 column C.
(NOTE)
101. You reported a value in Part II, Section 8.7 column
B, however you did not report a quantity in Section
6.1 or a quantity with an appropriate M Code (M40,
M50, M54, M61, M69, M95) for treatment in Section
6.2 column C. Please provide a quantity in Section
6.1 or the appropriate quantity and M Codes for
treatment in Section 6.2 column C. (NOTE)
102. You have reported a listed metal or metal compound
category in Part II, Section 6.1, however you have
not provided a quantity released in section 8.1
column B. Note that in Section 8a, metal or metal
compound category can only be reported as disposed
or recycled and not reported as treated for energy
recovery or treated for destruction. Please provide
quantity released in pounds/year in Section 8.1
column B. (NOTE)
103. You have reported a listed metal or metal compound
category in Part II, Section 6.1, however you have
not provided quantity released in 8. Id Column B.
Note that in Section 8a, metal or metal compound
category can only be reported as disposed or recycled
and not reported as treated for energy recovery or
treated for destruction. Please provide quantity
released in pounds/year Section 8. IB. (NOTE)
Toxics Release Inventory Reporting Forms and Instructions
C-15
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Appendix D. Supplier Notification Requirements
EPA requires some suppliers of mixtures or other trade name
products containing one or more of the EPCRA section 313
chemicals to notify their customers. This requirement has been
in effect since January 1, 1989.
This appendix explains which suppliers must notify their
customers, who must be notified, what form the notice must
take, and when it must be sent.
D.1 Who Must Supply
Notification
You are covered by the section 313 supplier notification
requirements if you own or operate a facility which meets all
of the following criteria:
1. Your facility is in a North American Industry
Classification System (NAICS) code that corresponds
to Standard Industrial Classification [SIC] codes 20-
39;
2. You manufacture (including import) or process an
EPCRA section 313 chemical; and
3. You sell or otherwise distribute a mixture or other
trade name product containing the EPCRA section
313 chemical to either:
- A facility in a covered NAICS code (see
Table I).
- A person that then may sell the same mixture
or other trade name product to a firm in a
covered NAICS code (see Table I).
Note that you may be covered by the supplier notification
rules even if you are not covered by the section 313 release
reporting requirements. For example, even if you have
fewer than 10 full-time employees or do not manufacture or
process any of the EPCRA section 313 chemicals in sufficient
quantities to trigger the release and other waste management
reporting requirements, you may still be required to notify
certain customers.
D.2 Who Must Be Notified
Industries whose primary NAICS code does not correspond to
SIC codes 20 through 39 are not required to initiate the
distribution of notifications for EPCRA section 313 chemicals
in mixtures or other trade name products that they send to their
customers.
However, if these facilities receive notifications from their
suppliers about EPCRA section 313 chemicals in mixtures or
other trade name products, they should forward the
notifications with the EPCRA section 313 chemicals they send
to other covered users.
An example would be if you sold a lacquer containing toluene
to distributors who then may sell the product to other
manufacturers. The distributors are not in a covered NAICS
code, but because they sell the product to companies in
covered NAICS codes, they must be notified so that they may
pass the notice along to their customers, as required.
The language of the supplier notification requirements covers
mixtures or other trade name products that are sold or
otherwise distributed. The "otherwise distributes" language
includes intra-company transfers and, therefore, the supplier
notification requirements at 40 CFR Section 372.45 apply.
D.3 Supplier Notification
Content
The supplier notification must include the following
information:
1. A statement that the mixture or other trade name
product contains an EPCRA section 313 chemical or
chemicals subject to the reporting requirements of
EPCRA section 313 (40 CFR 372);
2. The name of each EPCRA section 313 chemical and
the associated Chemical Abstracts Service (CAS)
registry number of each chemical if applicable. (CAS
numbers are not used for chemical categories, since
they can represent several individual EPCRA section
313 chemicals.); and
3. The percentage, by weight, of each EPCRA section
313 chemical (or all EPCRA section 313 chemicals
within a listed category) contained in the mixture or
other trade name product.
For example, if a mixture contains a chemical (i.e., 12 percent
zinc oxide) that is a member of a reportable EPCRA section
313 chemical category (i.e., zinc compounds), the notification
must indicate that the mixture contains a zinc compound at 12
percent by weight. Supplying only the weight percent of the
parent metal (zinc) does not fulfill the requirement. The
customer must be told the weight percent of the entire
compound within an EPCRA section 313 chemical category
present in the mixture.
Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
D.4 How the Notification
Must Be Made
The required notification must be provided at least annually in
writing. Acceptable forms of notice include letters, product
labeling, and product literature distributed to customers. If
you are required to prepare and distribute a Material Safety
Data Sheet (MSDS) for the mixture under the Occupational
Safety and Health Act (OSHA) Hazard Communication
Standard, your section 313 notification must be attached to the
MSDS or the MSDS must be modified to include the required
information. (A sample letter and recommended text for
inclusion in an MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies or
redistribution of the MSD S or other form of notification must
include the section 313 notice. In other words, your customers
should understand their requirement to include the section 313
notification if they give your MSDS to their customers.
D.5 When Notification Must
Be Provided
You must notify each customer receiving a mixture or other
trade name product containing an EPCRA section 313
chemical with the first shipment of each calendar year. You
may send the notice with subsequent shipments as well, but it
is required that you send it with the first shipment each year.
Once customers have been provided with an MSD S containing
the section 313 information, you may refer to the MSDS by a
written letter in subsequent years (as long as the MSDS is
current).
If EPA adds EPCRA section 313 chemicals to the section 313
list, and your products contain the newly added EPCRA
section 313 chemicals, notify your customers with the first
shipment made during the next calendar year following EP A's
final decision to add the chemical to the list. For example, if
EPA adds chemical ABC to the list in September 1998,
supplier notification for chemical AB C would have begun with
the first shipment in 1999.
You must send a new or revised notice to your customers if
you:
1. Change a mixture or other trade name product by
adding, removing, or changing the percentage by
weight of an EPCRA section 313 chemical; or
2. Discover that your previous notification did not
properly identify the EPCRA section 313 chemicals
in the mixture or correctly indicate the percentage by
weight.
In these cases, you must:
1. Supply a new or revised notification within 30 days
of a change in the product or the discovery of
misidentified EPCRA section 313 chemical(s) in the
mixture or incorrect percentages by weight; and
2. Identify in the notification the prior shipments of the
mixture or product in that calendar year to which the
new notification applies (e.g., if the revised
notification is made on August 12, indicate which
shipments were affected during the period January 1 -
August 12).
D.6 When Notifications Are
Not Required
Supplier notification is not required for a "pure" EPCRA
section 313 chemical unless a trade name is used. The identity
of the EPCRA section 313 chemical will be known based on
label information.
You are not required to make a "negative declaration." That
is, you are not required to indicate that a product contains no
EPCRA section 313 chemicals.
If your mixture or other trade name product contains one of the
EPCRA section 313 chemicals, you are not required to notify
your customers if:
1. Your mixture or other trade name product contains
the EPCRA section 313 chemical in percentages by
weight of less than the following levels (These are
known as de minimis levels)
- 0.1 percent if the EPCRA section 313
chemical is defined as an "OSHA
carcinogen;"
1 percent for other EPCRA section 313
chemicals.
De minimis levels for each EPCRA section 313 chemical and
chemical category are listed in Table II. PBT chemicals
(except lead when contained in stainless steel, brass or bronze
alloys) are not eligible for the de minimis exemption.
Therefore, de minimis levels are not provided for these
chemicals in Table II. However, for purposes of supplier
notification requirements only, such notification is not required
when the following PBT chemicals are contained in mixtures
below their respective de minimis levels:
D-2
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Appendix D
Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds if the
dioxin and dioxin-like
compounds are present
as contaminants in a
chemical and if they
were created during the
manufacturing of that
chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
29082-74-4
40087-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
Supplier
notification
limit (%)
1.0
1.0
0.1
1.0*
0.1
0.1
1.0
0.1
o.r*
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1***
1.0
0.1
Chemical or chemical
category name
Trifluralin
CAS
number or
chemical
category
code
1582-09-8
Supplier
notification
limit (%)
1.0
*The de minimis level is 1.0 for all members except for
2,3,7,8-Tetrachlorodibenzo-p-dioxin which has a 0.1%
de minimis level.
**The de minimis level is 0.1 for inorganic lead
compounds and 1.0 for organic lead compounds
***The de minimis level is 0.1 except for
benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
benzo(j,k)fluorene, and 3-methylcholanthrene which are
subject to the 1.0% de minimis level.
Your mixture or other trade name product is one of
the following:
An article that does not release an EPCRA
section 313 chemical under normal
conditions of processing or otherwise use.
Foods, drugs, cosmetics, alcoholic
beverages, tobacco, or tobacco products
packaged for distribution to the general
public.
Any consumer product, as the term is defined
in the Consumer Product Safety Act,
packaged for distribution to the general
public. For example, if you mix or package
one-gallon cans of paint designed for use by
the general public, notification is not
required.
A waste sent off site for further waste management.
The supplier notification requirements apply only to
mixtures and trade name products. They do not
apply to wastes.
You are initiating distribution of a mixture or other
trade name product containing one or more EPCRA
section 313 chemicals and your facility is in any of
the covered SIC codes added during the 1997
industry expansion rulemaking, including facilities
whose SIC code is within SIC major group codes 10
(except 1011, 1081, and 1094), 12 (except 1241);
industry codes 4911 (limited to facilities that combust
coal and/or oil for the purpose of generating power
for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose
of generating power for distribution in commerce), or
493 9 (limited to facilities that combust coal and/or oil
for the purpose of generating power for distribution
in commerce); or 4953 (limited to facilities regulated
under the Resource Conservation and Recovery Act,
Toxics Release Inventory Reporting Forms and Instructions
D-3
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Appendix D
subtitle C, 42 U.S.C. Section 6921 et seq.) or 5169, Information retained under 40 CFR 372 must be readily
or 5171, or 7389 (limited to facilities primarily available for inspection by EPA.
engaged in solvents recovery services on a contract
or fee basis).
D.7 Trade Secrets
Chemical suppliers may consider the chemical name or the
specific concentration of anEPCRA section 313 chemical in a
mixture or other trade name product to be a trade secret. If
they consider:
1. The specific identity of an EPCRA section 313
chemical to be a trade secret, the notice must
contain a generic chemical name that is descriptive of
the structure of that EPCRA Section 313 chemical
(for example, decabromodiphenyl oxide could be
described as a halogenated aromatic);
2. The specific percentage by weight of an EPCRA
section 313 chemical in the mixture or other trade
name product to be a trade secret, the notice must
contain a statement that the EPCRA section 313
chemical is present at a concentration that does not
exceed a specified upper bound. For example, if a
mixture contains 12 percent toluene and you consider
the percentage a trade secret, the notification may
state that the mixture contains toluene at no more
than 15 percent by weight. The upper bound value
chosen must be no larger than necessary to
adequately protect the trade secret.
If you claim this information to be trade secret, you must have
documentation that provides the basis for your claim.
D.8 Record keeping
Requirements
You are required to keep records of the following for three
years:
1. Notifications sent to recipients of your mixture or
other trade name product;
2. All supporting materials used to develop the notice;
3. If claiming a specific EPCRA section 313 chemical
identity a trade secret, you should record why the
EPCRA section 313 chemical identity is considered a
trade secret and the appropriateness of the generic
chemical name provided in the notification; and
4. If claiming a specific concentration a trade secret,
you should record explanations of why a specific
concentration is considered a trade secret and the
basis for the upper bound concentration limit.
D-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix D
D.9 Sample Notification Letter
January 2, 2009
Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999
Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more chemicals subject to
section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are required to notify you of the presence of
these chemicals in the product under EPCRA section 313. This law requires certain industrial facilities to report on annual emissions
and other waste management of specified EPCRA section 313 chemicals and chemical categories. Our product contains:
• Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
• Zinc compounds, 15 percent.
If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more information, call the
EP A/TRI Information Center. For contact information, please see the TRI Home Page at http://www.epa.gov/tri. Your other suppliers
should also be notifying you about EPCRA section 313 chemicals in the mixtures and other trade name products they sell to you.
Finally, please note that if you repackage or otherwise redistribute this product to industrial customers, a notice similar to this one
should be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
Furniture Products
Toxics Release Inventory Reporting Forms and Instructions D-5
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Appendix D
D.10 Sample Notification on an MSDS Furniture Products
Section 313 Supplier Notification
This product contains the following EPCRA section 313 chemicals subject to the reporting requirements of section 313
of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):
CAS Number Chemical Name Percent by Weight
108-88-3 Toluene 20%
NA Zinc Compounds 15%
This information must be included in all MSDSs that are copied and distributed for this material.
Material Safety Data Sheet
D-6
Toxics Release Inventory Reporting Forms and Instructions
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Appendix E. TRI State Contacts
EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a current list of
state designated Section 313 contacts, see the TRI web site at:
State TRI Contact Information and Web Sites: http://www.epa.gov/tri/stateprograms/statejrograms.htm
Toxics Release Inventory Reporting Forms and Instructions
E-l
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Appendix F. TRI Regional Contacts
Region 1 (CT, ME, MA, NH, RI, and VT)
Dwight Peavey
Assistance and Pollution Prevention Office
USEPA Region 1 (SPT)
1 Congress Street, Suite 1100
Boston, MA 02114-2023
(617) 918-1829; fax: (617) 918-1810
peavey.dwight@epa.gov
Region 2 (NJ, NY, PR, and VI)
Nora Lopez
Pesticides and Toxic Substances Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(732) 906-6890; fax: (732) 321-6788
lopez.nora@epa.gov
Region 3 (DE, DC, MD, PA, VA, and WV)
William Reilly
Toxics Programs and Enforcement Branch
USEPA Region 3 (3WC33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2072; fax: (215) 814-3114
reilly.william@epa.gov
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Ezequiel Velez
EPCRA Enforcement Section
USEPA Region 4
Atlanta Federal Center
6IForsyth Street, S.W.
Atlanta, GA 30303-8960
(404) 562-9191; fax: (404) 562-9163
velez. ezequiel@epa. gov
Region 5 (IL, IN, MI, MN, OH, and WI)
Thelma Codina
Pesticides and Toxics Branch
USEPA Region 5 (DT-8J)
77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-6219; fax: (312) 353-4788
codina.thelma@epa. gov
Region 6 (AR, LA, NM, OK, and TX)
Morton Wakeland
Toxics Section, Multimedia Planning and Permitting
Division
USEPA Region 6 (6PD-T)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8116; fax: (214) 665-6762
wakeland.morton@epa.gov
Region 7 (IA, KS, MO, and NE)
Stephen Wurtz
Air, RCRA and Toxics Division
USEPA Region 7 (ARTD/CRIB)
901 North 5th Street
Kansas City, KS 66101
(913) 551-7315; fax: (913) 551-7065
wurtz. stephen@epa. gov
Region 8 (CO, MT, ND, SD, UT, and WY)
Barbara Conklin
Office of Pollution Prevention, Pesticides and Toxics
USEPA Region 8 (8P-P3T)
1595 Winkoop Street
Denver, CO 80202
(303) 312-6619; Fax: (303) 312-6044
Conklin.barbara@epa.gov
Region 9 (AS, AZ, CA, GU, HI, MH, MP, and
NV)
Nancy Levin
Toxics Office
USEPA Region 9 (CED-4)
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 972-3848; fax: (415) 947-3583
levin.nancy@epa.gov
Region 10 (AK, ID, OR, and WA)
Brook Madrone
Office of Waste & Chemical Management
USEPA Region 10 (AWT-128)
1200 Sixth Avenue
Suite 900
Seattle, WA 98101-3140
(206) 553-4016; Fax: (206) 553-8509
Madrone.brook@epa.gov
Toxics Release Inventory Reporting Forms and Instructions
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Appendix G. Other Relevant Section 313 Materials
G.1 Public Data Release
2007 Toxics Release Inventory Public Data Release
Report
TRI data collected from 1987 through 2007 can be accessed
using the TRI Explorer online tool:
http://www.epa.gov/triexplorer
as well as several other public access tools available on the
TRI website. In addition, users can obtain summary
information and access the TRI data submitted for reporting
years 1996 through 2007 via the web from the TRI Public Data
Release Internet site at
http://www.epa.gov/tri/tridata/index.htm. This Internet site
provides fast and easy access to the TRI data submitted for
each of these years, as well as an overview of the data and
other relevant TRI information regarding each year (including
tables, charts, maps, and a summary of key findings). EPA has
released two electronic publications summarizing the 2007
data: the 2007 TRI Public Data Release (PDR) Brochure
(EPA-260-R-09-001) and the 2007 Public Data Release
eReport. These reports provide an overview of the 2007 TRI
reporting year data and other information relating to TRI data.
The reports serve as a supplement to EPA's TRI Explorer
where, for example, users of TRI data can retrieve electronic
2007 state fact sheets that provide a snapshot of each state's
releases and other waste management activities and a
description of the information included in the state fact sheet.
G.2 Access to TRI
Information On-line
The TRI Home Page http://www.epa.gov/tri offers
information useful to both novice and experienced users of the
Toxics Release Inventory. It provides a description of what the
TRI database is and how it can be used; access to TRI data;
TRI regulations; and guidance documents for complying with
TRI regulations and using TRI data. You can find out about
TRI products, view or download the 2007 TRI data release
reports, and identify who to contact for more information in
EPA regions and state programs across the country. From the
TRI home page, you can link to other EPA and non-EPA sites
that also allow you to search the TRI database and other
databases online.
TRI Explorer http://www.epa.gov/triexplorer is an on-line
tool that EPA has created to obtain TRI data. It allows the
user to search the TRI database using six criteria: facility,
chemical, year or industry type (NAICS code), federal facility
and geographic area (at the county, state or national level).
The tool will generate three types of reports: (1) Release
Reports (including on- and off-site releases (i.e., off-site
releases include transfers off-site to disposal and metals and
metal compounds transferred to POTWs)); (2) Waste Transfer
Reports (including amounts transferred off-site for further
waste management but not including transfers off-site to
disposal); and (3) Waste Quantity Reports (including amounts
recycled, burned for energy recovery, quantities treated, and
quantities released).
TOXNET http://toxnet.nlm.nih.gov the National Library of
Medicine's (NLM) Toxicology Data Network, provides free
access to several databases, including the TRI database, that
provides a variety of information on toxic chemicals. As with
EPA's TRI Explorer tool, users of TOXNET can search by
chemical or other name, chemical name fragment, or Chemical
Abstracts Service Registry Number. Also searchable are
facility or parent company name, state, city, county, or zip
code. Search results can be limited to releases greater than a
specified number of pounds, and individual releases can be
summed together to display a total amount. Toxicity and
environmental fate data for thousands of chemicals are also
available from TOXNET.
G.3 Other TRI Information
EPA's Integrated Risk Information System (IRIS)
http://www.epa.gov/iris is an electronic database containing
information on human health effects that may result from
exposure to various chemicals, including TRI chemicals, in the
environment. IRIS was initially developed for EPA staff in
response to a growing demand for consistent information of
chemical substances for use in risk assessments, decision-
making and regulatory activities. The information in IRIS is
intended for those without extensive training in toxicology, but
with some knowledge of health sciences.
Consolidated List of Chemicals Subject to the Emergency
Planning and Community Right-to-Know Act and Section
112(r) of the Clean Air Act (List of Lists), (October 2001):
http://www.epa.gov/ceppo/pubs/title3.pdf
A paper copy is available from the National Technical
Information Service, 5285 Port Royal Road, Springfield, VA
22161, 703 605-6000, Document Number: PB2003-105834,
$38.00 plus $5.00 shipping and handling.
Chemicals in Your Community, A Citizen's Guide to the
Emergency Planning and Community Right-to-Know Act,
December 1999 (EPA 550-99-001).
This booklet is intended to provide a general overview of the
EPCRA requirements and benefits for all audiences. Part I of
the booklet describes the provisions of EPCRA and Part II
describes more fully the authorities and responsibilities of
groups of people affected by the law and is available through
Toxics Releases Inventory Forms and Instructions
G-l
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Appendix G
written request at no charge from the EPA/TRI Information
Center. For contact information, please see the TRI Home
Page at http://www.epa.gov/tri.
Chemicals in the Environment
Issue number 6 of Chemicals in the Environment (CIE),
published in the Fall of 1997, is devoted entirely to TRI. This
22 page publication contains 19 articles ranging from the
history of TRI to the future of new TRI products. Articles
include perspectives from the community, state, Federal, and
International level. The publication also provides valuable
information on training and contacts within the EPA. CIE is
available free from EPA by asking for publication EPA 749-R-
97- 00Ib. To request copies, contact:
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W.
Attn: TRI Documents
MC: 2844
Washington, DC 20460
202 564-9554
Email: TRIDOCS@epa.gov
The Pollution Prevention Information Clearinghouse
(PPIC) http://www.epa.gov/oppt/ppic/index.html
PPIC was established as part of EPA's response to the
Pollution Prevention Act of 1990, which directed the Agency
to compile information, including a database, on management,
technical, and operational approaches to source reduction.
PPIC provides information to the public and industries
involved in conservation of natural resources and in reduction
or elimination of pollutants in facilities, workplaces, and
communities.
To request EPA information on pollution prevention or obtain
fact sheets on pollution prevention from various state programs
call the PPIC reference and referral service at 202 566-0799,
or fax a request to 202 566-0794, or write to:
U.S. EPA
Pollution Prevention Information Clearinghouse (PPIC)
EPA West
1200 Pennsylvania Ave. NW
Room 3379 (Mail Code 7407-T)
Washington, DC 20460-0001
Email: ppic@epa.gov
G-2 Toxics Releases Inventory Forms and Instructions
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Appendix H. Guidance Documents
H.1 General Guidance
Many of the TRI guidance documents are available via the Internet http://www.epa.gov/tri.
• 40 CFR 372, Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule
A reprint of the final EPCRA section 313 rule as it appeared in the Federal Register (FR) February 16, 1988 (53
FR 4500) (OTSFR 021688).
• Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community
Right-to-Know Act
March 1995 (EPA 745R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the reporting requirements
of EPCRA section 313. The glossary was developed to aid in determining whether a facility manufactures,
processes, or otherwise uses a chemical subject to EPCRA section 313 reporting.
• EPCRA Section 313 Questions and Answers - Revised 1998 Version
December 1998 (EPA 745-B-98-004)
The revised 1998 EPCRA Section 313 Questions and Answers document assists regulated facilities in complying
with the reporting requirements of EPCRA section 313. This updated document presents interpretive guidance
in the form of answers to many commonly asked questions on compliance with EPCRA section 313. In
addition, this document includes comprehensive written directives to assist covered facilities in understanding
some of the more complicated regulatory issues. This updated guidance document is intended to supplement the
instructions for completing the Form R and the Alternate Threshold Certification Statement (Form A).
• EPCRA Section 313 Questions and Answers - Addendum to the Revised 1998 Version
December 2004 (EPA-260-B-04-002)
As a result of Executive Order 13148, regulatory actions, and legal decisions over the past five years, some of
the Qs & As contained in the 1998 Q &A Document were updated. The 1998 Q & A Document remains valid
guidance in all other respects.
• EPCRA Section 313 Questions and Answers Addendum for Federal Facilities
May 2000 (EPA 745-R-00-003)
This document is an addendum to the EPCRA section 313 Questions and Answers: Revised 1998 Version. It
provides additional assistance to federal facilities in complying with EPCRA section 313. Federal facilities,
which are subject to compliance under EPCRA through Executive Order 13423, frequently have operations that
are different from the private sector facilities subject to EPCRA. The document contains questions and answers
that address some of those differences.
• EPCRA Section 313 Release and Other Waste Management Reporting Requirements
February 2001 (EPA260/K-01-001)
The brochure alerts businesses to their reporting obligations under EPCRA section 313 and assists in
determining whether their facility is required to report. The brochure contains the EPA regional contacts, the list
of EPCRA section 313 toxic chemicals and a description of the Standard Industrial Classification (SIC) codes
subject to EPCRA section 313.
• Toxic Chemical Release Reporting Using 2007 North American Industry Classification System (NAICS)
Final Rule (73 FR 32466; June 9, 2008): This final rule incorporates 2007 Office of Management and Budget
(OMB) revisions and other corrections to the NAICS codes used for TRI Reporting.
Toxics Release Inventory Reporting Forms and Instructions H-1
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Appendix H
• Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Final
Rule (71 FR 32464; June 6,2006): With this rulemaking, Toxics Release Inventory (TRI) reporting will require
North American Industry Classification System (NAICS) codes in place of Standard Industrial Classification
(SIC) codes. North American Industry Classification System (NAICS), United States, 2002, Executive Office of
the President, Office of Management and Budget, NTIS Order Number: PB2002-101430
• Persistent Bioaccumulative Toxic (PBT) Chemicals; Final Rule (64 FR 58666)
A reprint of the final rule that appeared in the Federal Register of October 29, 1999. This rule adds certain PBT
chemicals and chemical categories for reporting year 2000 and beyond under EPCRA section 313, lowers their
activity thresholds and modifies certain reporting exemptions and requirements for PBT chemicals and chemical
categories. In a separate action, as part of the October 29, 1999 rulemaking, EPA added vanadium (except when
contained in alloy) and vanadium compounds. These are not listed as PBT chemicals.
H.2 Supplier Notification Requirements
(EPA 560-4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification requirements, gives examples
of situations which require notification, describes the trade secret provision, and contains a sample notification.
• Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2006 Version
February 2007 (EPA 260-C-06-901)
• Toxics Release Inventory: Reporting Modifications Beginning with 1995 Reporting Year
February 1995 (EPA 745-R-95-009)
• Trade Secrets Rule and Substantiation Form
• (53 FR 28772)
A reprint of the final rule that appeared in the Federal Register of July 29, 1988. This rule implements the trade
secrets provision of the Emergency Planning and Community Right-to-Know Act (section 322). The current
trade secret substantiation form can be accessed at http://www.epa.gov/tri/report/index.htarfforms
H.3 Chemical-Specific Guidance
EPA has developed a group of guidance documents specific to individual chemicals and chemical categories.
• Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals within the
Chlorophenols Category
June 1999 (EPA745-B-99-013)
• Toxics Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and Guidance for
Reporting
December 2000 (EPA745-R-00-004)
• Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting
Hydrochloric Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any
particle size)
December 1999 (EPA 745-B-99-014)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Releases
and Other Waste Management Activities of Toxic Chemicals: Lead and Lead Compounds
November 2001 (EPA-260-B-01-027)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Mercury and Mercury Compounds Category
August 2001 (EPA260-B-01-004)
H-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix H
• Toxics Release Inventory List of Toxic Chemicals within the Nicotine and Salt Category and Guidance for
Reporting
June 1999 (EPA745-R-99-010)
• Toxics Release Inventory List of Toxic Chemicals within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting
December 2000 (EPA 745-R-00-006)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals
August 2001 (EPA260-B-01-005)
• Toxics Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category and
Guidance for Reporting
June 1999 (EPA745-B-99-023)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals: Polycyclic Aromatic Compounds Category
August 2001 (EPA260-B-01-003)
• Toxics Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and Guidance
for Reporting
June 1999 (EPA745-R-99-011)
• Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting Sulfuric
Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any particle size)
March 1998 (EPA745-R-97-007)
• Toxics Release Inventory List of Toxic Chemicals within Warfarin Category
June 1999 (EPA745-B-99-011)
• Toxics Release Inventory List of Toxic Chemicals within Ethylenebisdithiocarbamic Acid, Salts and
Esters Category and List of Mixtures that Contain the Individually listed Chemicals Maneb, Metiram,
Nabam, and Zineb
September 2001 (EPA260-B-01-026)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Aqueous
Ammonia
December 2000 (EPA 745-R-00-005)
• Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
Chemicals within the Dioxin and Dioxin-like Compounds Category
December 2000 (EPA 745-B-00-021)
H.4 Industry-Specific Guidance
EPA has developed specific guidance documents for certain industries.
• EPCRA Section 313: Guidance for Chemical Distribution Facilities
January 1999 (EPA 745-B-99-005)
• EPCRA Section 313: Guidance for Petroleum Terminals and Bulk Storage Facilities
February 2000 (EPA 745-B-00-002)
• EPCRA Section 313: Guidance for Coal Mining Facilities
February 2000 (EPA 745-B-00-003)
Toxics Release Inventory Reporting Forms and Instructions H-3
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Appendix H
• EPCRA Section 313: Guidance for Electricity Generating Facilities
February 2000 (EPA 745-B-00-004)
• EPCRA Section 313 Reporting Guidance for Food Processors
September 1998 (EPA 745-R-98-011)
• EPCRA Section 313 Reporting Guidance for the Leather Tanning and Finishing Industry
April 2000 (EPA 745-B-00-012)
• EPCRA Section 313: Guidance for Metal Mining Facilities
Januaryl999 (EPA 745-B-99-001)
• Emergency Planning and Community Right-to-Know Act Section 313 Reporting Guidance for the
Presswood and Laminated Products Industry
August 2001 (EPA260-B-01-013)
• EPCRA Section 313 Reporting Guidance for the Printing, Publishing, and Packaging Industry
May 2000 (EPA 745-B-00-005)
• EPCRA Section 313: Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities
January 1999 (EPA 745-B-99-004)
• EPCRA Section 313 Reporting Guidance for Rubber and Plastics Manufacturing
May 2000 (EPA 745-B-00-017)
• EPCRA Section 313 Reporting Guidance for Semiconductor Manufacturing
July 1999 (EPA745-R-99-007)
• EPCRA Section 313 Reporting Guidance for the Textile Processing Industry
May 2000 (EPA 745-B-00-008)
• EPCRA Section 313 Reporting Guidance for Spray Application and Electrodeposition of Organic
Coatings
December 1998 (EPA 745-R-98-014)
H-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix I. Questions and Answers Regarding
Facility Identification Information
1.1 Categories
This document provides additional information about TRI
reporting procedures based on some frequently asked
questions. The questions and their answers are organized
into three groups:
Section 1.2 Identifying the parent company.
Section 1.3 Reporting after a change in name or
ownership.
Section 1.4 Reporting for multiple sites and/or owners.
1.2 Identifying the Parent
Company
A. Question
When a facility changes ownership after a Form R has been
submitted, who is required to respond to a Notice of
Noncompliance (NON) related to the Form R? Is the
current or prior owner/operator required to respond to the
NON?
A. Answer
The current owner/operator has the primary responsibility
for responding to a NON. However, all prior
owners/operators back to January 1 of the reporting year
may also be held responsible if the current owner/operator
does not respond to the NON in an accurate, complete, and
timely manner.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question 31 (EPA 745-B-97-008)).
B. Question
Who is the parent company for a 50/50 joint venture?
B. Answer
The 50/50 joint venture is its own parent company.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #33 (EPA745-B-97-008)).
C. Answer
Big Oil Corporation is the parent company.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #35 (EPA 745-B-97-008)).
1.3 Reporting After a
Change in Name or
Ownership
A. Question
The owner/operator of a covered facility is preparing Form
Rs for a facility. The facility and its parent company both
changed their names after the reporting year. What names
should be reported by the owner/operator (for both the
facility and the parent company) on the Form Rs covering
the reporting year?
A. Answer
The facility should report the names used by the facility and
parent company during that reporting year. When the
owner/operator submits Form Rs for the next reporting year,
these reports should reflect the names used by the facility
and parent company during the new reporting year. Note
that the TRI facility identification number will not change.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #457 (EPA 745-B-97-008)).
B. Question
If a covered facility does not have a Dun & Bradstreet
(D&B) number but the parent corporation does, should this
number be reported?
B. Answer
Report the D&B number for the facility. If a facility does
not have a D&B number, enter "NA" in Part I, Section 4.7.
The corporate D&B number should be entered in Part I,
Section 5.2 relating to parent company information.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #464 (EPA 745-B-97-008)).
C. Question
Mom and Pop Plastics is a wholly owned subsidiary of a
major chemical company which is a wholly owned
subsidiary of Big Oil Corporation, located in St. Paul,
Minnesota. Which is the parent company?
C. Question
In October 2009, Facility X changes ownership and is
purchased by Company Y. For the 2009 reporting year,
which facility is obligated to submit the Form R or Form A,
and whose name and what TRI identification number should
be on the form?
C. Answer
The owner or operator of the facility on the annual July 1
reporting deadline (i.e., Company Y) is primarily
Toxics Release Inventory Reporting Forms and Instructions
1-1
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Appendix I
responsible for reporting the data for the entire previous
year's operations at that facility. Any other owner or
operator of the facility before the reporting deadline may
also be held liable. The form submitted for a given reporting
year must reflect the names used by the facility and its
parent company on December 31 of that reporting year,
even if the facility changed its name or ownership at any
time during the reporting year. In this scenario, because
Facility X changed ownership before December 31 of the
reporting year, Company Y's name should appear on the
form. The TRI identification number is location-specific;
thus, the identification number will stay the same even if the
facility changes names, production processes, or NAICS
codes.
(Source: Monthly Call Center Report Question EPA530-R-
98—5j; October 1998).
1.4 Reporting for Multiple
Sites and/or Owners
A. Question
If two plants are separate establishments under the same site
management, must they have separate D&B numbers?
A. Answer
They may have separate D&B numbers, especially if they
are distinctly separate business units. However, different
divisions of a company located at the same facility usually
do not have separate D&B numbers.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #465 (EPA745-B-97-008)).
B. Question
An electricity generating facility (EOF) is comprised of
multiple independent owners. Each individual owner runs
his/her own separate operation, but each has a financial
interest in the operation of the entire facility. What name
should be entered as the parent company in Part I, Section
5.1 of the Form R? Should the facility report under one
holding company name?
B. Answer
The EGF should enter in Part I, Section 5.1 of the Form R
the name of the holding or parent company, consortium,
joint venture, or other entity that owns, operates, or controls
the facility.
(Source: Question #2, Addendum to the Guidance
Documents for the Newly Added Industries (EPA 745-B-
98-001)).
C. Question
A covered facility sells one of its establishments to a new
owner. The operator of the newly sold establishment,
however, does not change. The same operator operates the
newly sold establishment and the rest of the facility.
Although the facility makes its threshold determinations
based on the activities at the entire facility (including the
newly sold establishment), the facility chooses to report
separately for the different establishments. What parent
name should the newly sold establishment use, the parent
name of the owner or the parent name of the operator (i.e.,
the same as the rest of the facility)?
C. Answer
All establishments of a covered facility must report the
parent name of the facility. Therefore, in the instance
described above, the newly sold establishment should use
the parent name of the facility operator (i.e., the same parent
name the rest of the facility is using).
(Source: Spring Training 1998).
D. Question
Company A purchases a facility from Company B between
January 1, 2006 and June 30, 2006. For the 2005 reporting
year, which company's name and identification number
should appear on the Form R or Form A submission?
D. Answer
In the case that a facility is purchased between January 1
and June 30, the form submitted for the previous year must
reflect the name used by the facility on December 31 of that
reporting year. In this example, company B's name should
appear on the form because it owned the facility for the
duration of the reporting year. The TRI identification
number is location-specific; thus, the identification number
will stay the same even if the facility changes names,
production processes, or NAICS codes.
With regard to reporting, the owner or operator of the
facility on the annual July 1 reporting deadline (Company
A) is primarily responsible for reporting the data for the
previous year's operations at that facility. However, all prior
owners and operators back to January 1 of the year covered
in the report may also be held responsible if the current
owner or operator does not submit a report.
(Source: Monthly Call Center Report Question EPA530-R-
98—5j; October 1998)
E. Question
Two distinct NAICS code operations that are covered under
EPCRA Section 313 (e.g., an electricity generating unit and
a cement plant) are located on adjacent properties and are
owned by the same parent company. The two operations are
operated completely independently of one another (e.g.,
separate accounting procedures, employees, etc.). Are these
two operations considered one facility under EPCRA
Section 313?
1-2
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Appendix I
E. Answer
Yes. Under EPCRA Section 313, a facility is defined as, "all
buildings, equipment, structures, and other stationary items
which are located on a single site or on contiguous or
adjacent sites and which are owned or operated by the same
person." Because these two operations are located on
adjacent properties and are owned by the same person they
are considered one facility for EPCRA Section 313
reporting purposes. Additional information can be found in
the 2009 Toxic Release Inventory Reporting Forms and
Instructions.
F. Question
A piece of contiguous property consists of three covered
sites with various buildings, structures and equipment. The
three sites are owned by two different companies -
Company A and Company B. All three sites operate
completely independently of each other and have separate
personnel, finances, and environmental reporting systems.
Site 1 and its buildings and structures are owned and
operated by Company A and site 3 and its buildings and
structures are owned and operated by Company B. The
middle site, site 2 and its surrounding buildings and
structures, are owned by Company A and operated by
Company B. Are all three sites and their buildings and
structures considered separate facilities under EPCRA
Section 313? Who is responsible for reporting for each?
F. Answer
Under 40 CFR Section 372.3 a facility is defined as "all
buildings, equipment, structures, and other stationary items
which are located on a single site or on contiguous or
adjacent sites and which are owned or operated by the same
person." Because all buildings and structures located on
sites 1 and 2 are located on contiguous property and are
owned by the same person, they are considered one facility.
Because all buildings and structures located on sites 2 and 3
are located on contiguous property and are operated by the
same person, they are also considered one facility.
Therefore, for purposes of determining thresholds, the toxic
chemicals manufactured, processed, and otherwise used at
site 2 must be counted toward both Facility A's and Facility
B's threshold determinations. Because the operator is
primarily responsible for reporting, estimating and reporting
releases and other waste management calculations for sites 2
and 3 are the primary responsibility of Company B, and the
release and other waste management reporting for site 1 is
the primary responsibility of Company A. EPA allows the
release and other waste management reporting to be done in
this manner to avoid "double counting" releases and waste
management activities at site 2. However, provided
thresholds have been exceeded, if no reports are received
from a covered facility, determinations can be found in the
2009 Toxic Release Inventory Reporting Forms and
Instructions.
Toxics Release Inventory Reporting Forms and Instructions 1-3
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